EPA REGION 9 GRANTS HANDBOOK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
U.S. EPA Region 9 | 75 Hawthorne Street, San Francisco CA 94105
Serving Arizona, California, Hawaii, Nevada, Pacific Islands and 148 Tribes
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PHOTO INFORMATION: Top:
Middle:
Bottom
Supai Falls, Havasupai (Arizona)
Mariposa Grove, Yosemite (California)
Pineapple Plantation (Hawaii)
Sand Dunes (Nevada)
Flowering Plant (Saipan-Commonwealth of the
Northern Mariana Islands)
Revised February 22, 2021 (Second Revision)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901
Dear EPA Grant Applicants and Grant Recipients,
In 2010, the EPA Region 9 Grants Branch released a Grants Handbook to address the needs of grant
applicants and recipients, including key topics related to applying for, managing and closing-out an EPA
grant. With the recent introduction and availability of the EPA Grants Management Training for
Applicants and Recipients modules (https://www.epa.gov/grants/epa-grants-management-training-
applicants-and-recipients), there is a need to update the 2010 Grants Handbook to reflect important
changes. This 2020 Grants Handbook complements the information provided in the training modules
and helps establish a solid foundation for understanding EPA's grant requirements.
We hope that you will find the information in the Grants Handbook useful, and we thank you for your
interest in becoming an EPA grant recipient applicant or grant recipient.
Sincerely,
The EPA Region 9 Grants Branch
DISCLAIMER: The Region 9 Grants Handbook provides recipient tools for
managing EPA grants. It includes links to Federal resources to help grant
applicants and recipients in applying for and managing grants. All recipients are
required to comply with the standard terms and conditions and applicable statutes
and regulations governing their assistance agreements.
This document does not represent EPA 's approval or disapproval of any particular
action conducted by grant applicants or recipients, nor does it constitute legal
advice.
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EPA REGION 9 GRANTS HANDBOOK
Table of Contents
O GRANT PREAWARD PHASE l
The EPA Grant Lifecycle 2
Putting Together the EPA Grant Application Package 3
Application for Federal Assistance SF-424 (Sample) 4-8
Budget Detail (Sample) 9-12
EPA Key Contacts Form (Sample) 13-14
Preaward Compliance Review Report (Sample) 15-17
Certification Regarding Lobbying (Sample) 18
Workplan (Sample Cover Page) 19
Application Package Requirements & the EPA Grant Funding Process 20
Two Types of EPA Grants: Project & Continuing Environmental Program Grants 21-22
Allowability of Costs 23
Cost-Share/Matching Funds 24
Formula for Calculating Cost-Share/Matching Funds 25
Indirect Costs (Overhead) 26
Indian Organization Indirect Cost Negotiation Agreement (Sample) 27-29
Grant Work Plan 30
Procuring Goods and Services: Requirements 31
Procurement Practices 32-35
All About the Rules: EPA Grant Regulations & the Uniform Grants Guidance 36-37
Subawards 38
Monitoring and Managing Subawards 39
EPA and Related Federal Agency Internet Resources 40
Tribal Internet Resources 41
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© GRANT POSTAWARD PHASE 42
The EPA Grant Award 43
Grant Award Sample 44-50
Grant Payments 51
RAIN-2018-G06: EPA Requirements for Enrolling in the Automated Standard Application for
Payments (ASAP) System and Disbursing EPA Funds Within 5 Business Days of Drawdown 52-53
Timekeeping 54
The Federal Financial Report (SF 425 Form) 55
Federal Financial Report Sample and Instructions 56-62
Understanding the MBE/WBE Utilization Form 63-64
Requesting Changes to a Grant Agreement 65
Post Award Changes to Assistance Agreements Requiring Prior Approval 66
Post Award Changes for States & Local Governments 67
Post Award Changes for Tribes 68
Sample of a Rebudget Request (email correspondence) 69
Sample of a Rebudget Request (old and new budget) 70
Managing Unspent (Unexpended/Unobligated) Grant Funds 71
Keeping Records of the Grant's Financial Transactions 72
© GRANT CLOSEOUT PHASE 73
Equipment Disposition Requirements for Non-Superfund Grants 74
Record Retention Requirements (EPA Grants Except Superfund Cooperative Agreements) 75
Tips for Achieving Financial & Administrative Management Success 76-77
EPA Region 9 Commonly-Used Acronyms 78-80
How to Reach Us: The EPA Region 9 Grants Branch 81
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GRANT PREAWARD PHASE
This section provides information on how to apply for an EPA grant, develop a Budget Detail, calculate cost-share (if applicable),
complete and submit the grant application forms and other required documentation.
The federal government's grant opportunity website Grants.gov and the Catalog of Federal Assistance (CFDA)
beta.SAM.gov are the two sites for finding grant opportunities. Grants.gov provides more than 1,000 grant programs
and enables electronic grant application. In addition, many EPA programs post information about open competitive and
non-competitive grant opportunities on their websites. For example, Region 9's Brownfields Program provides
information on how to apply, eligibility and requirements for submitting application. Each of EPA's active grant
programs are listed in the Catalog of Federal Domestic Assistance (CFDA) along with all Federal agencies grant
opportunities. The CFDA provides information on grant program objectives, types of eligible organizations, application,
and award procedures. To search the CFDA, visit beta.SAM.gov.
A one-time Grants.gov registration is required to apply for any federal funding opportunity. Grant applicants must
ensure that their organizations have registered with the federal government's System for Award Management (SAM).
Registering in SAM is free and can take up to several weeks to complete.
Starting December 2020, the DUNS number will no longer be the official identifier for doing business with the U.S.
Government. Through December 2020, government systems will be transitioning from the DUNS to a SAM-generated
Unique Entity Identifier (UEI) https://www.gsa.gov/about-us/organization/federal-acquisition-service/office-of-svstems-
management/integrated-award-environment-iae/iae-information-kit/unique-entitv-identifier-update. All EPA grant
applicants are advised to read this link to understand the process of applying for a UEI or obtaining the new UEI number
assigned for existing DUNS-issued entities by SAM.gov.
Where to Find Grant Opportunities
Grants.gov, Unique Entity Identifier (UEI) and SAM.gov
DUNS IS
GOING
AWAY on
SAM.gov
t
Starting December 2020, the DUNS number will no longer be used as an official identifier on SAM.gov.
Instead, a SAM-generated Unique Entity Identifier (UEI) will be assigned. Get the details on
https://www.asa.aov/about-us/oraanization/federal-acquisition-service/office-of-svstems-
manaaement/intearated-award-environment-iae/iae-information-kit/unique-entitv-identifier-
update.
'X.
V
/
I
1
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The EPA Grant Lifecyle
2
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Putting Together the EPA Grant Application Package
After identifying an EPA funding opportunity that may be of interest to the organization, the following pages are samples
of the required forms and information necessary for preparing and submitting the grant application package.
All EPA Region 9 grant application package must contain all these forms, and the next pages provide samples for each
required form.
1 ¦ SF424 Application for Federal Assistance
2. SF424A
Section A Budget Information Non-Construction Programs
Section B Budget Categories
Section C Non-Federal Resources
3 ¦ Budget Detail - (See Budget Development Guidance link under "How Do I Create
a Revision-Free Budget Detail below and page 9)
4 ¦ EPA 5700-54 EPA Key Contacts Form
5 ¦ EPA 4700-4 Preaward Compliance Review Report for All Applicants and
Recipients Requesting Federal Financial Assistance
6 b Final/Approved Grant Workplan
7 ¦ Current Indirect Rate Cost Negotiation Agreement (if applicable)
8 b EPA 6600-06 Certification Regarding Lobbying (see submission rule below)
9 ¦ SF-LLL Disclosure of Lobbying Activities (if applicable)
10. EPA Financial Conflict of Interest Policy (if applicable*)
Notes & Tips for Completing the Grant Application Package
How often should I submit the
Certification Regarding
Lobbying Form 6600-06?
How do I create a revision-free
Budget Detail?
It should be submitted for all new grant applications with
funding request totaling over $100,000, or amendment grants
that have reached the cumulative total over $100,000. This
form is submitted one time for the life of the grant.
Most grant application errors occur in the Budget Detail.
Some common mistakes are: mis-categorization of budget line
items, mis-calculation of indirect costs and missing cost-share
amounts. This Budget Development Guidance provides
instructions and a sample on how to create a quality Budget
Detail: RAIN-2019-G02: Interim General Budget Development
Guidance for Applicants and Recipients of EPA Financial
Assistance: https://www.epa.Rov/Rrants/rain-2019-R02
* EPA Conflict of Interest Policy: https://www.epa.gov/grants/epas-financial-assistance-conflict-interest-policv
3
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SAMPLE
OMB Number: 4040-0004
Expiration Date: 12/31/2019
Application for Federal Assistance SF-424
I * 2. Type of Application:
* If Revision, select appropriate letter(s):
| | Preapplication
|x~l Application
| | Changed/Corrected Application
| | New
Q Continuation
| | Revision
* Other (Specify):
* 3. Date Received:
4. Applicant Identifier:
Completed byGrants.gov upon submission.
5a. Federal Entity Identifier:
LEAVE BLANK
5b. Federal Award Identifier:
LEAVE BLANK
State Use Only:
6. Date Received by State:
7. State Application Identifier: LEAVE BLANK
8. APPLICANT INFORMATION:
* a. Legal Name: | AZ Raging Waters
[
' b. Employer/Taxpayer Identification Number (EIN/TIN):
99-9999999
" c. Organizational DUNS:
999999999
d. Address:
* Streetl:
Street2:
* City:
County/Parish:
* State:
Province:
* Country:
|^23^Grand^Canyon^RoacT
Lava Falls
Dry County
AZ
USA: UNITED STATES
|82109
e. Organizational Unit:
Department Name:
Office of Rapids
Division Name:
f. Name and contact information of person to be contacted on matters involving this application:
Prefix:
Middle Name:
* Last Name:
Suffix:
Mr.
* First Name:
Chilly
Waters
Title: Project Manager
Organizational Affiliation:
AZ Raging Waters
* Telephone Number: |^819-482-9346^
* Email: | cwater@az.org
Fax Number:
4
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SAMPLE
Application for Federal Assistance SF-424
' 9. Type of Applicant 1: Select Applicant Type:
: A: State Government
Type of Applicant 2: Select Applicant Type:
Type of Applicant 3: Select Applicant Type:
' Other (specify):
10. Name of Federal Agency:
Environmental Protection Agency
11. Catalog of Federal Domestic Assistance Number:
66.805
CFDA Title:
Leaking Underground Storage Tank Trust Fund Corrective Action Program
12. Funding Opportunity Number:
EPA-CEP-02
• Title:
13. Competition Identification Number:
Title:
14. Areas Affected by Project (Cities, Counties, States, etc.):
Lava Falls, Dry County, AZ
Add Attachment
Delete Attachment
View Attachment
15. Descriptive Title of Applicant's Project:
Attach supporting documents as specified in agency instructions.
Add Attachments
Delete Attachments
View Attachments
5
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SAMPLE
Application for Federal Assistance SF-424
16. Congressional Districts Of:
* a. Applicant
04
' b. Program/Project |^04^
Attach an additional list of Program/Project Congressional Districts if needed.
Add Attachment
Delete Attachment
View Attachment
17. Proposed Project:
[
* a. Start Date: 1 10/01/2020
* b. End Date: I 9/30/2021
18. Estimated Funding ($):
* a. Federal
* b. Applicant
* c. State
* d. Local
* e. Other
* f. Program Income
* g. TOTAL
$252,574
$ 29,099
$281,673
* 19. Is Application Subject to Review By State Under Executive Order 12372 Process^
m a. This application was made available to the State under the Executive Order 12372 Process for review on
| | b. Program is subject to E.O. 12372 but has not been selected by the State for review.
| | c. Program is not covered by E.O. 12372.
4/1/2020
' 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes," provide explanation in attachment.)
~ Yes [X] No
If "Yes", provide explanation and attach
Add Attachment
Delete Attachment
View Attachment
21. *By signing this application, I certify (1) to the statements contained in the list of certifications** and (2) that the statements
herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances** and agree to
comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may
subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 218, Section 1001)
LEL
I AGREE
** The list of certifications and assurances, or an internet site where you may obtain this list, is contained in the announcement or agency
specific instructions.
Authorized Representative:
Ms.
Prefix:
Middle Name:
* Last Name: [^Geyser
Suffix:
* First Name: |^Crystal_
• Title:
Director
•Telephone Number: | 819-482-5555"
Fax Number:
Email:
ccje^ser(ffiaz;orc|_
' Signature of Authorized Representative:
Completed by Grants.gov upon submission.
Date Signed: Completed byGrants.gov upon submission.
6
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7,142
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7,325
156,720
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RAIN-2019-G02: Interim General Budget Development Guidance
for Annlicants and Recipients of EPA Financial Assistance
https://www.epa.gov/grants/rain-2019-g02
-Budget Detail/Narrative — Sample from Appendix 2 of RAIN-2019-G02
*Please note Both federal and non-federal funds must be listed in the budget detail/narrative*
Background. This fictitious sample budget detail/narrative is based on a hypothetical EPA assistance
agreement supporting an Urban Waters project that involves water quality sampling, analysis of the
results, and outreach to the community to encourage efforts to improve water quality. The agreement
requires a recipient cost share of 10% of total project costs.
Notes:
- The applicant should identify its equipment cost threshold if it is lower than the $5,000 level specified
at 2 CFR 200.33.
- The sample calls for the applicant to attach its negotiated indirect cost rate agreement. If anapplicant
does not have an indirect cost rate it should attach an explanation of how indirect costs, if any, are
determined in accordance with the budget guidance. For more information about indirect costs, refer to
indirect cost policy, guidance, and training in RAIN-2018-G02.
Budget Detail/Narrative Sample:
Personnel:
Requested from
EPA
Cost Share
provided by
applicant
(if applicable)
Total
Salaries and Wages
(1) Project Manager
@ $47/hr x 323 hours
$15,181
$15,181
(1) Project Assistant @ $24/hr x 200 hours
$4,800
$4,800
(1) Community Relations Coordinator @ $23/hr
x 150 hours
$3,450
$3,450
Total
$18,631
$ 4,800
$23,431
Fringe Benefits:
Cost Share
Rate/Base/C omposition
Requested from
provided by
Total
EPA
applicant
(if applicable)
31% of Personnel costs (FICA, retirement, health,
vacation, sick leave)
$5,776
$1,488
$7,264
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Travel:
See Narrative Note 1.
Requested from
EPA
Cost Share
provided by
applicant
(if applicable)
Total
2 National Conferences including lodging, air,
per-diem and registration fees for 2 employees.
(See Narrative Note 2.)
$4,492
$4,492
Local travel for sampling and meetings. (P.O. Y.
@ $0.58 per mile and actual cost for public
transit)
$150
$150
Travel to one-week training course on innovative
sampling techniques including lodging, train and
per-diem for 1 employee. (See Narrative Note 3.)
$2,500
$2,500
Total
$7,142
$7,142
Equipment: (Equipment Capitalization Threshold = $5,000)
Description
Purpose
Unit Cost
Quantity
Requested
from EPA
Cost Share
provided
by
applicant
(if
applicable)
Total
Microwave
Digester
Lab
Analysis
$17,500
1
$17,500
$17,500
12 Foot Motorized
Skiff and trailer.
(See Narrative
Note 4.)
Sampling
1
$6,000
$6,000
Total
$23,500
$23,500
Supplies
Type
Requested from
EPA
Cost Share
provided by
applicant
(if applicable)
Total
Computer Software
$2,500
$2,500
Office Supplies (pens, pencils, paper, chairs,
etc.)
$825
$825
2 Lap Top Computers @ $2000 each.
$4,000
$4,000
Total
$7,325
$7,325
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Contractual
Contractual *
(competitive process will be used to determine
contractors when required by regulation)
Cost Share
Requested from
EPA
provided by
applicant
(if applicable)
Total
Advertising for public meetings (Newspapers)
$1,000
$1,000
Environmental Sampling Firm to design
sampling protocol and assist with data
evaluation.
$120,000
$20,000
$140,000
Community Meeting Facilitator - $524/ day x
30 days (rate complies with limitation on
individual consultant fees)
$15,720
$15,720
Total
$136,720
$20,000
$156,720
Other
Type
Requested from
EPA
Cost Share
provided by
applicant
(if applicable)
Total
Postage for Flyers for Community meetings.
$611
$611
Subaward to Friends of the Wolf River (See
Narrative Note 5)
$30,000
$30,000
Participant Support Cost: Travel to National Conference
for 4 Community Members (See Narrative Note 6)
$9,000
$1,000
$10,000
Printing Costs (Occasional use of large copiers
at Office Depot).
$1,200
$1,200
Total
$39,000
$2,811
$41,811
Indirect Costs:
Base (See Narrative Note 7)
Requested from
EPA
Cost Share
provided by
applicant
(if applicable)
Total
26% of Personnel and Fringe Benefits and first
$25,000 of Subaward Costs
$14,480
$14,480
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Total Budget Summary
Requested from
EPA
Cost Share provided
by applicant
(if applicable)
Total
Personnel
$18,631
$ 4,800
$23,431
Fringe Benefits
$5,776
$1,488
$7,264
Travel
$7,142
$7,142
Equipment
$23,500
$23,500
Supplies
$7,325
$7,325
Contractual
$136,720
$20,000
$156,720
Other
$39,000
$2,811
$41,811
Indirect Costs
$14,480
$14,480
Total
$252,574
$29,099
$281,673
Recipient cost share calculation: $29,099 / $281,673 = 10.33%
Narrative Note 1. There is no international travel for this project.
Narrative Note 2. The Project Manager and Community Relations Coordinator will make presentations
on interim and final project results at the 2019 and 2020 National Urban Waters conferences. Travel
reimbursement will be based on GSA per-diem rates.
Narrative Note 3. The Program Assistant will attend a one-week training on innovative sampling
techniques at Tulane University.
Narrative Note 4. Our equipment threshold is $5,000. We have determined based on the frequency and
timing of the sampling activity that purchasing a small motorized skiff and a trailer is more cost
effective than boat rentals. Additionally, some sampling will take place in remote areas in which boat
rentals are not available.
Narrative Note 5. We will partner with Friends of the Wolf River to encourage community participation
in the project. Friends is a 501(c)(3) nonprofit organization that promotes conservation of the Wolf
River. Among other things, Friends will pay stipends and travel support to community members who
attend focus groups and participate in training to prevent disposal of cooking grease in household drains.
Friends of Wolf River understands that the stipends and participant travel are Participant Support costs
that are excluded from its Modified Total Direct Cost base for distributing indirect costs.
Narrative Note 6. Four community members (non-staff) will attend the 2019 and 2020 NationalUrban
Waters conferences (two at each conference) to participate in our presentations.
Narrative Note 7. We have attached our most recent negotiated indirect cost rate agreement.
16 12
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SAMPLE
EPA KEY CONTACTS FORM
OMB Number: 2030-0020
Expiration Date: 04/30/2021
Authorized Representative: Original awards and amendments will be sent to this individual for review and acceptance, unless
otherwise indicated.
Name: Prefix:
First Name:
Crystal
Last Name:
Geyser
Title:
Director
Complete Address:
Streetl:
Street2:
City:
123 Grand Canyon Road
Lava Falls
Zip / Postal Code:
Phone Number:
E-mail Address:
82109
819-482-5555
cwater@az.org
Middle Name:
Suffix:
State:
Country:
AZ
Fax Number:
Payee: Individual authorized to accept payments.
Name: Prefix:
First Name:
Last Name:
Forest
Title:
Comptroller
Complete Address:
Streetl:
Street2:
City:
123 Grand Canyon Road
Lava Falls
Zip / Postal Code:
Phone Number:
E-mail Address:
82109
819-482-9348
gforest@az.org
Green
Middle Name:
Suffix:
State:
Country:
AZ
Fax Number:
Administrative Contact: Individual from Sponsored Programs Office to contact concerning administrative matters (i.e., indirect cost
rate computation, rebudgeting requests etc).
Name:
Title:
Prefix:
First Name:
Chilly
Last Name:
Waters
Middle Name:
Suffix:
Project Manager
Complete Address:
Streetl:
123 Grand Canyon Road
Street2:
City:
Zip / Postal Code:
Phone Number:
E-mail Address:
Lava Falls
82109
State:
Country:
AZ
819-482-9346
Fax Number:
cwater@az.org
EPA Form 5700-54 (Rev 4-02)
13
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EPA KEY CONTACTS FORM
Project Manager: Individual responsible for the technical completion of the proposed work.
Name: Prefix:
First Name:
Savanna
Last Name:
Plains
Title:
Manager
Complete Address:
Streetl:
Street2:
City:
123 Grand Canyon Road
Lava Falls
Zip / Postal Code:
Phone Number:
E-mail Address:
82109
State:
Country:
AZ
819-482-9344
Middle Name:
Suffix:
Fax Number:
splains@AZ.org
EPA Form 5700-54 (Rev 4-02)
14
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SAMPLE
OMB Number: 2030-0020
Expiration Date: 04/30/2021
Preaward Compliance Review Report for
All Applicants and Recipients Requesting EPA Financial Assistance
Note: Read Instructions before completing form.
I. A. Applicant/Recipient (Name, Address, City, State, Zip Code)
Name:
Address:
City:
State:
Do Not Leave Blank
Zip Code:
B. DUNS No. Recipient DUNS Number
Choose one
Is the applicant currently receiving EPA Assistance? Q Yes | | No
List all civil rights lawsuits and administrative complaints pending against the applicant/recipient that allege discrimination based on
race, color, national origin, sex, age, or disability. (Do not include employment complaints not covered by 40 C.F.R. Parts 5 and 7.)
Do Not Leave Blank (i.e., N/A, None, or Yes)
IV. List all civil rights lawsuits and administrative complaints decided against the applicant/recipient within the last year that allege
discrimination based on race, color, national origin, sex, age, or disability and enclose a copy of all decisions. Please describe all
corrective actions taken. (Do not include employment complaints not covered by 40 C.F.R. Parts 5 and 7.)
Do Not Leave Blank
List all civil rights compliance reviews of the applicant/recipient conducted by any agency within the last two years and enclose a copy
of the review and any decisions, orders, or agreements based on the review. Please describe any corrective action taken.
(40 C.F.R. § 7.80(c)(3))
Do Not Leave Blank
VI. Is the applicant requesting EPA assistance for new construction? If no, proceed to VII; if yes, answer (a) and/or (b) below.
~ Yes Q No <- Choose One
a. If the grant is for new construction, will all new facilities or alterations to existing facilities be designed and constructed to be readily
accessible to and usable by persons with disabilities? If yes, proceed to VII; if no, proceed to Vl(b).
| | Yes Q No
b. If the grant is for new construction and the new facilities or alterations to existing facilities will not be readily accessible to and usable
by persons with disabilities, explain how a regulatory exception (40 C.F.R. 7.70) applies.
Choose - Do Not Leave Blank
VII.
Does the applicant/recipient provide initial and continuing notice that it does not discriminate on the basis
of race, color, national origin, sex, age, or disability in its program or activities? (40 C.F.R 5.140 and 7.95)
~
Yes
~
No
a.
Do the methods of notice accommodate those with impaired vision or hearing?
~
Yes
~
No
b.
Is the notice posted in a prominent place in the applicant's offices or facilities or, for education programs
and activities, in appropriate periodicals and other written communications?
~
Yes
~
No
c.
Does the notice identify a designated civil rights coordinator?
~
Yes
~
No
VIII.
Does the applicant/recipient maintain demographic data on the race, color, national origin, sex, age, or
handicap of the population it serves? (40 C.F.R. 7.85(a))
~
Yes
~
No
IX.
Does the applicant/recipient have a policy/procedure for providing access to services for persons with
limited English proficiency? (40 C.F.R. Part 7, E.O. 13166)
~
Yes
~
No
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X.
If the applicant is an education program or activity, or has 15 or more employees, has it designated an employee to coordinate its
compliance with 40 C.F.R. Parts 5 and 7? Provide the name, title, position, mailing address, e-mail address, fax number, and telephone
number of the designated coordinator.
Do Not Leave Blank
XI. If the applicant is an education program or activity, or has 15 or more employees, has it adopted grievance procedures that assure the
prompt and fair resolution of complaints that allege a violation of 40 C.F.R. Parts 5 and 7? Provide a legal citation or Internet Address
for, or a copy of, the procedures.
Do Not Leave Blank
For the Applicant/Recipient
I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete. I acknowledge that any
knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. I assure that I will fully comply
with all applicable civil rights statutes and EPA regulations.
A. Signature of Authorized Official
Completed by Grants.gov upon submission.
For the U.S. Environmental Protection Agency
I have reviewed the information provided by the applicant/recipient and hereby certify that the applicant/recipient has submitted all preaward
compliance information required by 40 C.F.R. Parts 5 and 7; that based on the information submitted, this application satisfies the preaward
provisions of 40 C.F.R. Parts 5 and 7; and that the applicant has given assurance that it will fully comply with all applicable civil rights statures and
EPA regulations.
A. 'Signature of Authorized EPA Official B. Title of Authorized Official C. Date
B. Title of Authorized Official C. Date
Completed by Grants.gov
upon submission.
NOTE: Signature and date auto populates by Grants.gov once the AOR signs the SF424
16
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* See Instructions
Instructions for EPA FORM 4700-4 (Rev. 06/2014)
General. Recipients of Federal financial assistance from the U.S. Environmental Protection Agency must comply with the following statutes and
regulations.
Title VI of the Civil Rights Acts of 1964 provides that no person in the United States shall, on the grounds of race, color, or national origin, be
excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial
assistance. The Act goes on to explain that the statute shall not be construed to authorize action with respect to any employment practice of any
employer, employment agency, or labor organization (except where the primary objective of the Federal financial assistance is to provide
employment). Section 13 of the 1972 Amendments to the Federal Water Pollution Control Act provides that no person in the United States shall on
the ground of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under the Federal Water Pollution
Control Act, as amended. Employment discrimination on the basis of sex is prohibited in all such programs or activities. Section 504 of the
Rehabilitation Act of 1973 provides that no otherwise qualified individual with a disability in the United States shall solely by reason of disability be
excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial
assistance. Employment discrimination on the basis of disability is prohibited in all such programs or activities. The Age Discrimination Act of 1975
provides that no person on the basis of age shall be excluded from participation under any program or activity receiving Federal financial assistance.
Employment discrimination is not covered. Age discrimination in employment is prohibited by the Age Discrimination in Employment Act administered
by the Equal Employment Opportunity Commission. Title IX of the Education Amendments of 1972 provides that no person in the United States on
the basis of sex shall be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education
program or activity receiving Federal financial assistance. Employment discrimination on the basis of sex is prohibited in all such education programs
or activities. Note: an education program or activity is not limited to only those conducted by a formal institution. 40 C.F.R. Part 5 implements Title IX
of the Education Amendments of 1972. 40 C.F.R. Part 7 implements Title VI of the Civil Rights Act of 1964, Section 13 of the 1972 Amendments to
the Federal Water Pollution Control Act, and Section 504 of The Rehabilitation Act of 1973. The Executive Order 13166 (E.O. 13166) entitled;
"Improving Access to Services for Persons with Limited English Proficiency" requires Federal agencies work to ensure that recipients of Federal
financial assistance provide meaningful access to their LEP applicants and beneficiaries.
Items "Applicant" means any entity that files an application or unsolicited proposal or otherwise requests EPA assistance. 40 C.F.R. §§ 5.105, 7.25.
"Recipient" means any entity, other than applicant, which will actually receive EPA assistance. 40 C.F.R. §§ 5.105, 7.25. "Civil rights lawsuits and
administrative complaints" means any lawsuit or administrative complaint alleging discrimination on the basis of race, color, national origin, sex, age,
or disability pending or decided against the applicant and/or entity which actually benefits from the grant, but excluding employment complaints not
covered by 40 C.F.R. Parts 5 and 7. For example, if a city is the named applicant but the grant will actually benefit the Department of Sewage, civil
rights lawsuits involving both the city and the Department of Sewage should be listed. "Civil rights compliance review" means any review assessing
the applicant's and/or recipient's compliance with laws prohibiting discrimination on the basis of race, color, national origin, sex, age, or disability.
Submit this form with the original and required copies of applications, requests for extensions, requests for increase of funds, etc. Updates of
information are all that are required after the initial application submission. If any item is not relevant to the project for which assistance is requested,
write "NA" for "Not Applicable." In the event applicant is uncertain about how to answer any questions, EPA program officials should be contacted for
clarification. * Note: Signature appears in the Approval Section of the EPA Comprehensive Administrative Review For Grants/Cooperative
Agreements & Continuation/Supplemental Awards form.
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United States
ENVIRONMENTAL PROTECTION AGENCY
Washington, DC 20460
OMB Control No. 2030-0020
Approval expires 04/30/2021
Leave
This
EPA Project Control Number Blank
CERTIFICATION REGARDING LOBBYING
CERTIFICATION FOR CONTRACTS, GRANTS,
LOANS AND COOPERATIVE AGREEMENTS
The undersigned certifies, to the best of his or her knowledge and belief, that:
(1) No Federal appropriated funds have been paid or will be paid, by or on behalf of the
undersigned, to any person for influencing or attempting to influence an officer or
employee of any agency, a Member of Congress, an officer or employee of Congress, or
an employee of a Member of Congress in connection with the awarding of any Federal
contract, the making of any Federal grant, the making of any Federal loan, the entering
into of any cooperative agreement, and the extension, continuation, renewal,
amendment, or modification of any Federal contract, grant, loan, or cooperative
agreement.
(2) If any funds other than Federal appropriated funds have been paid or will be paid to
any person for influencing or attempting to influence an officer or employee of any
agency, a Member of Congress in connection with this Federal contract, grant, loan, or
cooperative agreement, the undersigned shall complete and submit Standard Form-LLL,
"Disclosure Form to Report Lobbying," in accordance with its instructions.
(3) The undersigned shall require that the language of this certification be included in the
award documents for all sub-awards at all tiers (including sub-contracts, sub-grants, and
contracts under grants, loans, and cooperative agreements) and that all sub-recipients
shall certify and disclose accordingly.
This certification is a material representation of fact upon which reliance was placed when this
transaction was made or entered into. Submission of this certification is a prerequisite for making
or entering into this transaction imposed by section 1352, title 31 U.S. Code. Any person who fails
to file the required certification shall be subject to a civil penalty of not less than $10,000 and not
more than $100,000 for each such failure.
Crystal Geyser
Typed Name & Title of Authorized Representative
Signature and Date of Authorized Representative
The public reporting and recordkeeping burden for this collection of information is estimated to average 15 minutes per response.
Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division,
U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number
in any correspondence. Do not send the completed form to this address.
EPA Form 6600-06 (Rev. 06/2014) Previous editions are obsolete.
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WORK PLAN
Lust Trust Fund (LUST) Corrective Action Program
10/01/2020-09/30/2021
Attach to each application: a required work plan
(This Sample is only the cover page of work plan)
Each Program may have different work plan requirements. Check with your EPA
Project Officer.
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Application Package Requirements & The EPA Grant Funding Process
EPA follows the following sequence for overseeing the implementation of non-competitive and competitive grant
opportunities. Applicants must use Grants.gov (https://www.grants.gov/) to submit a grant application package.
1 ¦ EPA posts competitive solicitations or Funding Announcements on Grants.gov for applicants to
apply/submit an application. For Continuing Environmental Programs, annual Program Guidance may be
posted EPA's website. Generally, on-going recipients will be sent a "Please Apply" notification via email, which
instructs the recipient that an application must be submitted for funding. The email will include, among other
information, the amount of funding available, workplan guidelines, the program contacts and grants specialist,
etc. In addition, generally, a Region 9 Applicant Guide will be attached which provides information for
Grants.gov and to assist in submitting a complete application. The applicant must use Grants.gov to submit
their complete proposal/application package consisting of:
The EPA Region 9 required application forms are:
1.
SF424 Application for Federal Assistance
2.
SF424A
Section A Budget Information Non-Construction Programs
Section B Budget Categories
Section C Non-Federal Resources
3.
Budget Detail - (See Budget Development Guidance information on page 3 and page 9)
4.
EPA 5700-54 EPA Key Contacts Form
5.
EPA 4700-4 Preaward Compliance Review Report for All Applicants and Recipients Requesting
Federal Financial Assistance
6.
Final/Approved Grant Workplan
7.
Current Indirect Rate Cost Negotiation Agreement (if applicable)
8.
EPA 6600-06 Certification Regarding Lobbying (see submission rule on page 3)
9.
SF-LLL Disclosure of Lobbying Activities (if applicable)
10.
EPA Financial Conflict of Interest Policy (if applicable, see page 3 for information)
A ¦ EPA Project Officer and the Grants Specialist review the grant application in its entirety for completeness
and correctness.
EPA Project Officer negotiates any outstanding workplan/budget issues with the applicant. Once negotiations
are completed, the EPA Project Officer recommends to the EPA Approval Official the application to be funded.
Once the EPA Approval Official approves the recommendations, then it moves to the EPA Grants Office for their
review of all federal requirement and preparation of award.
3 ¦ The EPA Award Official electronically approves/signs the official "Notice of Award." The EPA Grants
Specialist emails the award document to the recipient with instructions.
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Two Types of EPA Grants:
Project & Continuing Environmental Program Grants
Congress authorizes EPA grants through laws or statutes which specifies the type of eligible entities and activities the
funds can be used for. Project grants are generally competed programs and available to eligible entities. EPA's
Continuing Environmental Program (CEP) grants are usually formula grants that are awarded primarily to our on-going
recipients, I.e., state, tribal, and local governments. The amount of the CEP grant is generally determined by a formula
prescribed by the statute and implementing EPA regulations.
PROJECT GRANTS
A one-time assistance agreement; project
proposal is usually selected and awarded
through a competitive solicitation process
with a time-limit to achieve/complete its
purpose.
CONTINUING
ENVIRONMENTAL
PROGRAM (CEP)
GRANTS
Awarded non-competitivelyto
governmental units each year to support
on-going State, Tribal, and local
environmental programs.
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Examples of a Continuing Environmental Program & Project Grant
An example of a CEP grant:
WATER POLLUTION CONTROL PROGRAM
(Clean Water Act §106)
Grant #1
$65,000
10/1/2019
Starts
Grant #2
$65,000
9/30/2020
Ends
10/1/2020
Starts
09/30/2021
Ends
Grant's project period/cycle is set on a Fiscal Year (FY): State FY (July 1 to June 30) or
Federal FY (October 1 to September 30) or, in rare instances, Calendar Year (January 1 to
December 31)
Usually has a one-year period of performance (but, it can be up to 5 years); EPA and
recipient negotiates the grant's period of performance
Grant with a one-year period of performance are typically fully funded in a single award;
grant can be funded incrementally if the period of performance is two years or more
Final Federal Financial Report (FFR) is submitted 120 days after the grant's project period
end date; annual (interim) FFR is required if the grant's period of performance is more than
one year
I*" An example of a Project grant:
WETLANDS PROTECTION DEVELOPMENT
(Clean Water Act §104(b))
Grant (Initial Award)
Amendment #1
Amendment #2
$55,000
Add: $10,000
Add $-0-
Total: $65,000
Total: $65,000
11/15/2018
Starts
11/30/2019
11/30/2020
10/31/2021
Ends
• Variable period of performance
• Funds may or may not be added to finish project
• Project period may be extended, without additional funds, to finish the project
• Annual (interim) Federal Financial Report (FFR) is required since the period of performance is
usually more than a year
• Final FFR is due 120 days after the grant's project period end date
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Allowability of Costs
Recipients of EPA grant payments must maintain a financial management system that meets the standards for fund control and
accountability. In general, costs must meet the basic criteria to be allowable under federal awards, including that it is necessary and
reasonable for the performance of the grant. A cost is reasonable if it does not exceed what a prudent person would pay under the
circumstances prevailing at the time the decision was made to incur the cost. "Prudence" refers to exercising sound business
judgement given a recipient's responsibility to use federal funds efficiently. Lastly, a cost is allowable to a grant if the goods or
services involved are chargeable or assignable to a cost objective in accordance with the relative benefits the grant receives.
Factors to Consider in Determining
if a Cost is Allowable:
1. Necessary and reasonable for the project being funded.
2. Eligible under the program that the project is funded by.
3. Allocable (can be allocated) to the project being funded.
4. Authorized and not prohibited by law or regulation.
5. Conform to limitations of laws, regulations, etc. and grant
terms and conditions.
6. Consistent with recipient's policies/procedures - same factors
apply to both federal and non-federal activities.
7. Accorded to consistent treatment - a cost may not be assigned
as direct if a similar cost incurred for the same purpose has
been allocated as indirect cost.
8. Not included as a cost or used to meet a matching requirement
for any other federal grant.
9. Consistent with generally accepted accounting principles.
10. Adequately documented.
\
\
EPA's COST PRINCIPLES
See 2 C.F.R. §§200.403 through
200.409 for more detailed
information.
2 CFR. Part 200 - Uniform
Administrative Requirements.
Cost Principles, and Audit
Requirements for Federal
Awards
For Continuing Environmental
Program (CEP) grants, see 40 CFR,
Part 35.
i
i
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Cost-Share/Matching Funds
Cost-Share/Matching Funds is the portion of allowable project costs a grant recipient or a third-party contributes to a grant or
cooperative agreement (2 CFR Part 200.306). There are two types of matching funds: Cash or In-Kind.
Yes
The following are examples of acceptable cash or in-kind contributions:
CASH
IN-KIND
- Personnel/fringe costs
- Personnel costs donated by another organization (not by
- Travel
employees)
- Equipment
- Services donated by another organization (not by recipient)
- Indirect Costs
- Volunteers (not employees)
- Money contributed by another
- Equipment donated either by recipient
organization or by individual to the
OR by another organization
recipient.
- Public Law 93-638 funds (Indian Self-
Determination Act)
¦ All match/cost sharing funds must have supporting source documents (a record that supports a transaction).
¦ Dollar values must be placed on all donated services. All match/cost sharing funds must be included in the
workplan and budget and be part of the grant's total project costs.
¦ All match/cost sharing funds must conform to the same laws, regulations, grant conditions, etc. as the federal
funds within the grant.
No
Items that CANNOT be used as match/cost share funds:
Other federal funds, except for Public Law (PL) 93-638 funds (Indian Self-Determination and Education
Assistance Act). (Note: Activities performed under PL 93-638 must be for similar program activities as the EPA-
funded program in order to qualify for its use as match.) PL 93-638 can be located at www.ihs.gov.
Unallowable/ Ineligible costs for the project/program.
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Formula for Calculating Cost-Share/Matching Funds
o
Example: Let's say the total Federal funds available is $100,000 and the recipient's required match is 20%; therefore, this
makes the Federal portion of the project to be 80% (i. e., 100% - 20% = 80%). Follow the steps below.
Divide the Total Federal Funds available ($100,000) by the maximum federal percentage allowed (80% or .80).
$100,000 -w .80 = $125,000 (total project cost)
$125,000 - $100,000 = $25,000
The minimum non-Federal contribution (20%) required is $25,000
If you know the total project cost;
1. Multiply the Total Project Cost amount by the required match
percentage.
2. The amount derived from step #1 is your MINIMUM required
match.
Example: Let's say $125,000 is the Total Project Cost and the recipient's required match is 20% (i.e., .20 of total project
cost). Follow the steps below.
$ 125,000 x.20 = $25,000
The required match the recipient must contribute to the grant is $25,000
If you know the total federal funds available:
1. Divide the Total Federal Funds available by the maximum
federal percentage allowed.
2. Subtract the amount of Total Federal Funds available from the
amount derived from step #1.
3. The amount derived from step #2 is the MINIMUM non-
federal contribution (match) required.
O
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Indirect Costs (Overhead)
Indirect costs are costs that benefit more than one cost objective and are not readily identifiable with a particular grant, contract, or
other activity, but are necessary to the overall operation of an organization, such as rent or utility costs. If your organization plans to
charge indirect costs to an EPA grant, your financial management system must provide for and describe existing or planned indirect
cost rate expenses (2 CFR §§ 200.412 - 200.419 and Appendices).
Differentiating Direct and Indirect Costs
DIRECT COSTS
Costs that can be assigned to a specific budget category
Personnel
Fringe
Travel
Eguipment
Supplies
Contractual
Other*
* Anticipated direct project charges that do not fit
in other budget categories. Examples:
Subawards, participant support costs, or rental
costs for space or equipment.
INDIRECT COSTS
Costs that are not readily identifiable with a particular activity but are
necessary to the general operation of the organization and the conduct
of the proposed project (such as general administration expenses).
• Costs of operating and maintaining facilities*
• Depreciation on buildings and eguipment
• General Administration and general expenses **
*Example: electricity, water, sewer, rent, telephones
**Examples: salaries and expenses of executive
officers, personnel administration, and accounting.
KEY POINTS TO KEEP IN MIND ABOUT INDIRECT COST RATES
1. Indirect cost proposals are due to your organization's cognizant agency within 6 months after your accounting year ends.
2. Lack of a current indirect cost rate may affect the budgetary accuracy, cash flow, and the ability to draw down funds, and
close expired grants.
3. The organization may only drawdown funds when the approved Indirect Costs Rate Agreement is in place for that
specified period. Otherwise, the organization will not be able to draw down indirect costs for that time period.
4. If you budget an indirect rate lower than your approved rate, make sure you have your Finance Office approval in writing.
5. If your organization has never had a negotiated indirect cost rate, you may elect to charge a de minimis rate of 10% of
modified total direct costs.
6. Refer to EPA's policy on indirect cost at https://www.epa.gov/grants/rain-2018-g02 to learn about approved rate types
and additional guidance regarding the use of the 10% de minimis rate.
7. For submission requirements, refer to 2 CFR 200, Appendix V and VII. For more information on Indirect Cost Agreements
from IBC, refer to https://www.doi.gov/ibc/services/finance/indirect-cost-services.
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Indian Organizations
Indirect Cost Negotiation Agreement
EIN: 12-3456789
Organization: Date: December 20, 2 019
Arizona Raging Waters Report No(S).:01-A-lll
123 Grand Canyon Road
Lava Falls, AZ 82109
Filing Ref.:
Last Negotiation Agreement
dated 10/30/2019
The indirect cost rates contained herein are for use on grants, contracts and other
agreements with the Federal Government to which Public Law 93-638 and 2 CFR Part 200
apply for fiscal years beginning on or after December 26, 2014, subject to the
limitations contained in 25 CFR 900 and Section II.A. of this agreement. Applicable OMB
Circulars and the regulations at 2 CFR 225 will continue to apply to federal funds
awarded prior to December 26, 2014. The rates were negotiated by the U.S. Department of
the Interior, Interior Business Center, and the subject organization in accordance with
the authority contained in applicable regulations.
Section I: Rates
Effective Period Applicable
Type From To Rate* Locations To
Fixed Carryforward 1/01/2020 12/31/2020 37.91%** All BIA Programs
Fixed Carryforward 1/01/2020 12/31/2020 37.68% All All Other
* Base: Modified total direct costs, less capital expenditures and passthrough funds.
Passthrough funds are normally defined as major subcontracts, payments to participants,
stipends to eligible recipients, and subgrants, all of which normally require minimal
administrative effort.
**The rate for BIA programs was calculated using the Benchmarking Methodology stipulated
in the Equitable Relief Orders filed by the U. S. District Court of New Mexico on June 1,
2011.
Treatment of fringe benefits: Fringe benefits applicable to direct salaries and wages are
treated as direct costs; fringe benefits applicable to indirect salaries and wages are
treated as indirect costs.
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Section II: General
A. Limitations: Use of the rates contained in this agreement is subject to any
applicable statutory limitations. Acceptance of the rates agreed to herein is predicated
upon these conditions: (1) no costs other than those incurred by the subject organization
were included in its indirect cost rate proposal, (2) all such costs are the legal
obligations of the recipient/contractor, (3) similar types of costs have been accorded
consistent treatment, and (4) the same costs that have been treated as indirect costs
have not been claimed as direct costs (For example, supplies can be charged directly to a
program or activity as long as these costs are not part of the supply costs included in
the indirect cost pool for central administration).
B. Audit: All costs (direct and indirect, federal and non-federal) are subject to audit.
Adjustments to amounts resulting from audit of the cost allocation plan or indirect cost
rate proposal upon which the negotiation of this agreement was based will be compensated
for in a subsequent negotiation agreement.
C. Changes: The rates contained in this agreement are based on the organizational
structure and the accounting system in effect at the time the proposal was submitted.
Changes in organizational structure, or changes in the method of accounting for costs
that affect the amount of reimbursement resulting from use of the rate in this agreement,
require the prior approval of the responsible negotiation agency. Failure to obtain such
approval may result in subsequent audit disallowance.
D. Provisional/Final Rates: Within 6 months after yearend, a final rate must be
submitted based on actual costs. Billings and charges to contracts and grants must be
adjusted if the final rate varies from the provisional rate. If the final rate is
greater than the provisional rate and there are no funds available to cover the
additional indirect costs, the organization may not recover all indirect costs.
Conversely, if the final rate is less than the provisional rate, the organization will be
required to pay back the difference to the funding agency.
E. Fixed Carryforward Rate: The fixed carryforward rate is based on an estimate of costs
that will be incurred during the period for which the rate applies. When the actual
costs for such period have been determined, an adjustment will be made to the rate for a
future period, if necessary, to compensate for the difference between the costs used to
establish the fixed rate and the actual costs.
F. Agency Notification: Copies of this document may be provided to other federal offices
as a means of notifying them of the agreement contained herein.
G. Record Keeping: Organizations must maintain accounting records that demonstrate that
each type of cost has been treated consistently either as a direct cost or an indirect
cost. Records pertaining to the costs of program administration, such as salaries,
travel, and related costs, should be kept on an annual basis.
H. Reimbursement Ceilings: Recipient/contractor program agreements providing for
ceilings on indirect cost rates or reimbursement amounts are subject to the ceilings
stipulated in the contract or grant agreements. If the ceiling rate is higher than the
negotiated rate in Section I of this agreement, the negotiated rate will be used to
determine the maximum allowable indirect cost.
I. Use Of Other Rates: If any federal programs are reimbursing indirect costs to this
recipient/contractor by a measure other than the approved rates in this agreement, the
recipient/contractor should credit such costs to the affected programs, and the approved
rate should be used to identify the maximum amount of indirect cost allocable to these
programs.
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J. Central Service Costs: Where central
of indirect cost rates, adjustments will
provisional and final amounts.
service
be made
costs are estimated for the calculation
to reflect the difference between
K. Other:
1. The purpose of an indirect cost rate is to facilitate the allocation and billing of
indirect costs. Approval of the indirect cost rate does not mean that an organization
can recover more than the actual costs of a particular program or activity.
2. Programs received or initiated by the organization subsequent to the negotiation of
this agreement are subject to the approved indirect cost rate if the programs receive
administrative support from the indirect cost pool. It should be noted that this could
result in an adjustment to a future rate.
3. New indirect cost proposals are necessary to obtain approved indirect cost rates for
future fiscal or calendar years. The proposals are due in our office 6 months prior to
the beginning of the year to which the proposed rates will apply.
Section III: Acceptance
Listed below are the signatures of acceptance for this agreement:
By the Indian Organization: By the Cognizant Federal Government Agency:
/s/
/s/
Arizona Raging Waters
Craig A. Wills
Name
Name
Office Chief
Office of Indirect Cost Services
Director
Title
Title
U.S. Department of the Interior
Interior Business Center
11/10/2019
Date
Agency
Date
10/30/2019
Negotiated by Jane Doe
Telephone (916) 566-7111
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Grant Work Plan
The Work Plan is an integral piece of the grant application package because it provides EPA's basis for making an award. When
applying under competitive opportunities, Section IV (Proposal and Submission Information) of the solicitation announcement
outlines the information that is required in the work plan. For non-competitive opportunities, the appropriate program office will
provide instruction on what needs to be included.
Components of the Grant Work Plan
1 ¦ Outline all activities to be performed under
the grant; summarize deliverables; and include a
schedule for milestones, project completion, and
deliverables.
2 ¦ Include a budget narrative that links the
budget to work plan activities.
3_ Describe the need for the project, project
objectives, project methods, and anticipated
environmental results.
Provide a framework for managing the project
and performance measures for evaluating
performance, including how they will be used to
help track, measure, and report progress toward
achieving the expected outputs and outcomes.
5_ Describe the approach, procedures, and
controls for ensuring that awarded grant funds will
be expended in a timely and efficient manner.
KEY POINTS
The work plan should also clearly address the
evaluation criteria listed in the competitive
solicitation announcement and explains how the
project meets the criteria.
It should clearly explain what the project expects to
accomplish, and it should make clear why the
application is worthy of funding.
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Procuring Goods and Services: Requirements
The epa s Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance
Agreements is designed to ensure that purchases are obtained at a reasonable price in a fair and competitive way. Failure to
follow proper procurement practices is often an audit finding that leads to questioned costs.
D Recipient must use its own written procurement procedures which reflect applicable State, local, and tribal
laws and regulations, provided that the procurements conform to applicable federal law and federal
procurement standards. (2 CFR §200.318(a))
B Recipient must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders. (2 CFR §200.318(b))
B Recipient must maintain written standards of conduct covering conflicts of interest and governing the actions
of its employees engaged in the selection, award and administration of contracts. No employee, officer, or
agent may participate in the selection, award, or administration of a contract supported by a federal award if
he or she has a real or apparent conflict of interest. (2 CFR §200.318(c)(1))
DThe non-Federal entity must maintain records sufficient to detail the history of procurement. These records will
include but are not necessarily limited to the following: rationale for the method of procurement, selection of
contract type, contractor selection or rejection, and the basis for the contract price. (2 CFR §200.318(i))
BAN procurement actions must be conducted in a manner providing full and open competition consistent with
federal standards. (2 CFR §200.319(a))
NOTE: 2 CFR §200.317 - Procurements by states. When procuring property and services under a
Federal award, a State must follow the same policies and procedures it uses for procurements from its non-
Federal funds. The State will comply with §§200.321, 200.322, and 200.323 and ensure that every purchase
order or other contract includes any clauses required by §200.327.
EPA Requirements Regarding Procurements:
Learn more
about
procurements
requirements
EPA-Specific Procurement Standards: 2 CFR §§ 1500.10 -1500.11
Procurement Standards: 2 CFR § 200 Subpart D (200.317 - 200.327)
Participation by Disadvantaged Business Enterprises under EPA Programs: 40
CFR § 33
EPA-Specific Procurement Standards for Superfund Programs: 40 CFR § 35
Subpart O (35.6550 - 35.6610)
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Procurement Practices
The EPA's Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance
Agreements provides detailed guidance, including outlining the difference between procurement contracts and
subawards and detailing requirements for competition, hiring consultants, and documenting purchasing decisions.
EPA strongly recommends that recipients consult this guide during procurements.
BOOKMARK RECOMMENDATION: Best Practice Guide for Procuring Services, Supplies,
and Equipment Under EPA Assistance Agreements
https://www.epa.qov/qrants/best-practice-quide-procurinq-services-supplies-and-
eauipment-under-epa-assistance-aqreements
This section provides a summary on procurement methods, guidelines on contracts and consultants. It is not a
substitute for the more robust description of purchasing requirements in the EPA Best Practice guide.
Procurement Methods (2 CFR § 200.320)
(See also: RAIN-2018-G04 Micro-Purchases & Simplified Acquisition Threshold)
1) Micro-Purchase
¦ Aggregate dollar amount of which does not exceed the Micro-purchase threshold (2 CFR §200.67), which is
currently set at $10,000
¦ May be awarded without soliciting competitive quotations if recipient determines the price to be reasonable
¦ To the extent practicable, recipient must distribute micro-purchases equitably among qualified suppliers
2) Small Purchase
¦ Simple and informal procurement methods for securing services, supplies, or other property that do not cost
more than the Simplified Acquisition Threshold, which is currently set at $250,000
¦ Price or rate quotations must be obtained from an adequate number of qualified sources
3) Sealed Bid (formal advertising)
¦ Publicly solicited and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder
whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in
price
¦ Preferred method for construction
4) Competitive Proposals
¦ Normally conducted with more than one source submitting an offer, and either a fixed price or cost-
reimbursement type contract is awarded
¦ Generally used when conditions are not appropriate for sealed bids
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Types of Contracts
¦ Fixed-price contracts are used when there will likely be effective competition based on a complete
product description and clear plans and specifications. As provided at 2 CFR 200.320(b)(l)(ii),
recipients must use fixed price contracts in sealed bid situations. Recipients may use fixed priced
contracts in other situations as well.
a. There should not be any significant technical or engineering unknowns.
b. The contractor furnishes the goods or services for the fixed-price, and so assumes significant
risk. Profit is not typically stated or negotiated separately.
• Cost-reimbursable contracts are used when it is not feasible to award a fixed price contract.
a. The contractor's cost and profit are typically negotiated separately. The contractor
satisfactorily completes only the amount of work equivalent to the estimated cost to qualify for
the negotiated profit; the contractor may not complete the entire project.
b. The contractor assumes less risk than under a fixed price contract. Alternatively, recipient may
negotiate a cost-reimbursable contract that includes a ceiling that may not be exceeded but
requires completion of the work. In this situation, the risk to the contractor is increased.
• Time and Materials contracts are used only in circumstances in which no other contracting
instrument is available, and there is a cap on the amount of the contract that the contractor exceeds
at its own risk (2 CFR 200.318(j)). A time-and-materials contract is one in which the contract price is
the sum of the cost of materials plus fixed labor hours that are "loaded" with wages, overhead, and
profit such that the contractor has no incentive to control costs. Additional information on time and
materials contract rules is available at 2 CFR 200.318(j)(2).
• "Cost Plus" contracts are prohibited per 2 CFR 200.324(d). Percentage of construction cost and cost
plus a percentage cost contracts provide an incentive for the contractor to increase costs in order to
increase profit.
Procurement Rules on Contracts and Individual Consultants
Two issues that frequently arise are long-term contracts and sole-source contracts. Below are excerpts regarding
these two issues from EPA's Best Practice Guide.
Contracts
1) Long-Term Contracts:
• Recipients may enter into competitively-awarded long-term (generally not to exceed five years) contracts for
professional services or equipment leases that include options for periodic renewals. If the long-term contract
precedes the EPA assistance agreement, recipients may use that contract if it was procured competitively
consistent with Federal financial assistance regulations (including DBE considerations) in effect at the time.
The use of such contracts in EPA assistance agreements does not constitute sole source procurement since
the original contract was competed.
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• Long-term contracts that were awarded without competition may not meet EPA's minimum requirements for
compliance with 2 CFR § 200, Subpart D, Procurement Standards.
2) Sole-Source Contracts:
• Sole-source contracts in excess of the micro-purchase threshold should be rare. Potential
justifications include 2 CFR §200.320(c)(2), only one source has the goods or is able to perform the
service, 2 CFR §200.320(c)(3), an emergency, 2 CFR §200.320(c)(4) EPA approval, or 2 CFR
§200.320(c)(5) after soliciting a number of sources the recipient reasonably decided competition
was inadequate.
• EPA's general policy is to require competition in accordance with 2 CFR § 200, Subpart D,
Procurement Standards for commercially available items (including consulting services). EPA
recommends that recipients consult with EPA prior to making sole source procurements. Recipients
may proceed with sole source procurements if it falls under 2 CFR Part §200.320(c)(2), (3), or (5)
provided that a justification is shared with EPA. For 2 CFR §200.320(c)(4) EPA approval, recipients
may request a sole source procurement and provide a justification.
• EPA staff may not suggest, recommend, or direct recipients to hire particular firms or individuals.
• EPA does not require recipients to identify contractors in proposals. The fact that a recipient has
named a contractor in its proposal as a "partner" or otherwise does not justify a sole-source award.
If, at any time, EPA finds that a sole-source contract does not comply with EPA's interpretation, EPA
may disallow all or part of the cost of the contract as provided at 2 CFR § 200.339.
Payment to Individual Consultants (2 CFR § 1500.10)
> EPA will limit its participation in the salary rate (excluding overhead) paid to individual consultants retained by
recipients or by a recipient's contractors or subcontractors to the maximum daily rate for level 4 of the
Executive Schedule unless a greater amount is authorized by law. Recipients may pay consultants more than
this amount with non-EPA funds; however, this cost paid by the recipient cannot be applied toward required
cost-share by the EPA grant program.
> This limitation applies to consultation services of designated individuals with specialized skills who are paid at
a daily or hourly rate.
> This rate does not include transportation and subsistence costs for travel performed; recipients will pay these
in accordance with their normal travel reimbursement practices.
> Contracts with firms for services which are awarded using the procurement standards under 2 CFR §200
Subpart D are not affected by this limitation.
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EPA issued a Federal ReRister Notice (Vol. 69, No.67 dated April 7, 2004) wherein the formula to calculate the
individual consultant hourly and daily rate cap is as follows. The rates of pay for Executive Schedule is located at
https://www.opm.Rov/policv-data-oversiRht/pay-leave/salaries-waRes/
The Executive Schedule IV salary is $172,500 per year as of January 1, 2021 and 2,087 is the number of work hours
per year.
$172,500 -f 2,087 = $82.65 per hour
$82.65 x 8 hours = $661.24 per day
EPA Review of Documentation (2 CFR § 200.324)
The recipient must make available, upon request by EPA, technical specifications on proposed procurements where EPA
believes such review is needed to ensure that the item or service specified is the one being proposed for acquisition. This
review generally will take place prior to the time the specification is incorporated into a solicitation document. However, if
EPA desires to have the review accomplished after a solicitation has been developed, EPA may still review the
specifications, with such review usually limited to the technical aspects of the proposed purchase.
35
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All About the Rules: EPA Grant Regulations &
the Uniform Grants Guidance
The Uniform Grants Guidance (UGG) includes the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards codified in regulations located in 2 Code of Federal Regulations (CFR) Part 200. 2 CFR Part 200 serves as a
government-wide framework for grants management and provides an authoritative set of rules and requirements for federal grant
awards. 2 CFR Part 200 provides useful information about grant requirements, such as standards for financial and program
management and how to identify allowable costs. Under 2 CFR 1500, EPA adopted the regulations at 2 CFR 200 and promulgated
additional regulations specific to EPA.
Question:
Where do I find the comprehensive set of information
on rules and requirements for federal grant awards?
Answer:
CFR: Code of Federal Regulations
(Commonly known as the Uniform Grant
Guidance (UGG) or Omni Circular)*
2 CFR. Part 200 - Uniform Administrative
Requirements. Cost Principles, and Audit
Requirements for Federal Awards
^Supersedes requirements previously specified in 40 CFR Part
30 & 31,0MB Circulars A-21, A-87, A-102, A-110, A-122, and
A-133
Questions: Answer:
What are the specific cost items that are allowed in a Cost Principles
9rant- 2 CFR. Part 200. Subpart E - Cost Principles
What costs cannot be budgeted in a grant?
How can we charge indirect (overhead) costs?
How do we track personnel costs? (compensation) and
how much detail is required?
Is the cost of our single audit allowable?
Questions: Answer:
How often do we need an audit performed? Audit Requirements:
Who must perform the audit? 2 CFR 200 Subpart F - Audit Requirements
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What does the audit cover?
What standards must the audit follow?
What kind of a report is required?
NOTE:
The current threshold that triggers a single audit is
$750,000 in total federal funds spent in a recipient's
fiscal year.
Question:
Answer:
Where to I find the supplemental to 2 CFR 200, Subparts
A through F for EPA's policies and procedures for
financial assistance administration?
2 CFR. Part 1500 - Uniform Administrative
Requirements. Cost Principles, and Audit
Requirements for Federal Awards 2 CFR.
Part 1500
Questions:
What's the Disadvantage Business Enterprises in EPA
Programs?
Are we required to file annually?
What is the threshold amount for reporting?
Where can I find the MBE/WBE form?
Answer:
Disadvantage Business Enterprises (DBE)
or MBE/WBE
40 CFR. Part 33 - Participation by Disadvantaged
Business Enterprises (DBE) in EPA Programs
¦ DBE participation must be reported on EPA Form
5700-52A, by recipients when the budget for
procuring construction, equipment, services,
supplies, and subawards (under 'Other') exceeds
$250,000 (Simplified Acquisition Threshold).
¦ DBE reporting forms are due every October 30th to
EPA.
¦ Class Exception for MBE/WBE Fair Share Objectives
37
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Subawards
Under some grant projects, the primary grant recipient, referred to as the pass-through entity, will make awards, called
subawards, to other organizations for certain activities. A subaward is when an organization receives an award of financial
assistance from the pass-through entity to carry out part of the pass-through entity's grant project. Subawards do not include
purchased goods and services or payments to program beneficiaries. By contrast, a procurement contractor is a company,
individual consultant, instructor or other expert who is not an employee of the recipient that receives grant funding to provide
commercially available goods or services. (2 CFR §§200.331 - 200.333)
Is it a Subaward or a Contract?
EPA provides detailed guidance differentiating procurement contracts and subawards. With rare exceptions, EPA
considers transactions between recipients and for-profit companies or individual consultants and instructors to be
procurement contracts.
SUBAWARD
CONTRACT
A subaward is for the purpose of carrying out a portion of a
federal award and creates a federal assistance relationship
with the subrecipient. Characteristics that support the
classification of the non-federal entity as a subrecipient
include when the non-federal entity:
¦ Determines who is eligible to receive what federal
assistance;
¦ Has its performance measured in relation to whether
objectives of a federal program were met;
¦ Is responsible for adherence to applicable federal
program requirements specified in the federal award;
and
¦ In accordance with its agreement, uses the federal
funds to carry out a program for a public purpose
specific in authorizing statute, as opposed to goods or
services for the benefit of the pass-through entity
providing.
' ' Does the EPA
award include
Subaward
funding of an
amount equal to
or over $30,000?
A contract is for the purpose of obtaining goods and services for the non-
federal entity's own use and creates a procurement relationship with the
contractor. Characteristics indicative of a procurement relationship
between the non-federal entity and a contractor are when the contractor:
¦ Provides the goods and services within normal business operations;
¦ Provides similar goods or services to many different purchasers;
¦ Normally operates in a competitive environment;
¦ Provides goods or services that are ancillary to the operation of the
federal program; and
¦ Is not subject to compliance requirements of the federal program as a
result of the agreement, though similar requirements may apply for
other reasons.
If the answer is YES : In accordance with 2 CFR
Chapter 1, Part 170 Reporting Sub-award and Executive
Compensation Information, prime awardees awarded a
federal grant are required to file a FFATA sub-award
report by the end of the month following the month in
which the prime awardee awards any sub-grant equal
to or greater than $30,000. Click link to the Federal
Funding Accountability and Transparency Act
Subaward Reporting System (FSRS) for detailed
information.
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Monitoring & Managing Subawards
> The grant recipient must ensure that every subaward is clearly identified to the subrecipient as a subaward and
includes the following information at the time of the subaward and if any of these data elements change, include
the changes in subsequent subaward modification. (See §200.332(a) for full details.)
> The grant recipient must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations,
and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient
monitoring. (See §200.332(b) for full details.)
> The recipient must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for
authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the
subaward; and that subaward performance goals are achieved. (See §200.332(d) for full details.)
TRAINING & RESOURCES ON EPA's SUBAWARD POLICY
https://www.epa.gov/grants/grants-policv-issuance-gpi-16-01-epa-subaward-policv-epa-assistance-
agreement-recipients
Training
EPA Subaward Policy Training for EPA Assistance Agreement State Recipients
EPA Subaward Policy Training for EPA Assistance Agreement Non-State Recipients
EPA Subaward Policy Training Webinar for Recipients
Helpful Resources
EPA Subaward Frequent Questions as of November 6. 2018
EPA Subaward Cross Cutter Requirements
EPA Subaward Policy with attachments (PDF)
EPA Subaward Policy (PDF)
EPA Subaward Policy Appendix A: Distinctions Between Subrecipients and Contractors (PDF)
EPA Subaward Policy Appendix B: National Term and Condition for Subawards (PDF)
EPA Subaward Policy Appendix C: Model Programmatic Subaward Reporting Requirement (PDF)
EPA Subaward Policy Appendix D: Subaward Agreement Template (PDF)
39
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EPA and Related Federal Agency Internet Resources
EPA & FEDERAL
GOVERNMENT
INFORMATION
Examples of information/resources:
Finding grant opportunities
Applying for grants
Grants Training for Applicants & Recipients
Disadvantage Business Enterprises (MBE/WBE)
U.S. Federal Government websites
EPA Grants (EPA-National)
https://www.epa.qov/qrants
- Grant opportunities, application process, trainings, policies,
payment, & regulations (Uniform Grants Guidance UGG).
Grants.gov (Federal Grants)
https://www.epa.qov/qrants
- Search for grant programs available from 26+ federal agencies;
Applying for grants electronically
EPA Region 9 Grants
https://www.epa.qov/qrants/qrants-vour-reqion-information-
specific-epa-reqion-9
- Available regional grants, funding solicitations, Region 9
Application Guide (Application Checklist and instructions for
Grants.gov), other financial forms & instructions, EPA regulations
(40 CFR Part 35), Uniform Grants Guidance UGG (2 CFR Part 200).
EPA DBE & MBE/WBE Requirements
https://www.epa.gov/grants/disadvantaged-business-enterprise-
program-requirements
- Provides Minority Business & Women-Owned Business
Enterprise requirements for grants.
Paper Reduction Act
https://www.epa.qov/laws-requlations/summarv-paperwork-
reduction-act
- Information on EPA's information collection.
Environmental Federal Register Documents
http://www.epa.qov/fedrqstr/
Data Universal Numbering System (DUNS) number:
http://www.dnb.com/us/
Government Accounting Standards Board (GASB):
http://www.qasb.orq
40
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Tribal Internet Resources
TRIBAL
INFORMATION
Examples of information/resources:
Applying for a General Assistance Program (GAP) grant
Tribal consultations
Regional Tribal Operations Committee (RTOC meetings)
Region 9 Tribal contacts
Applying for an Indirect Rate Cost Agreement
¦ EPA Region 9 Tribal Programs
https://www.epa.qov/tribal/epas-pacific-southwest-tribal-
proaram
- Comprehensive website providing information on tribal
grants, tribal consultations, Regional Tribal Operations
Committee (RTOC) meetings, EPA Region 9 tribal contacts,
etc.
¦ EPA American Indian Environmental Office
http://www.epa.aov/indian/index.htm
- Comprehensive website providing information on tribal
grants, tribal consultations, Regional Tribal Operations
Committee (RTOC) meetings, EPA Region 9 tribal contacts,
etc.
¦ Tribal Indirect Cost Rates
- Information on indirect cost proposals, Department of
Interior staff contact, etc.
Dept. of Interior's National Business Center:
https://www.doi.gov/ibc/services/finance
Dept. of Health & Human Services
https://rates.psc.gov/
- List of approved indirect cost rates.
41
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e
GRANT POST AWARD PHASE
After accepting an award, the recipient is ready to start working on the activities outlined in the approved work plan.
Adhering to various grant regulations and the terms and conditions outlined in the grant agreement are critical to
ensuring a successful grant project. Various topics related to post-award grant management are covered in this section.
Annual To-Do Tasks: Post-Award EPA Reporting Requirements
Reports
Filing an Filing an Submitting
Annual annual Progress
(interim) MBE/WBE
SF425 Report
Federal (EPA Form
Financial 5700-52A)
Report
Reporting Due Date of
9/30 or 12/30
See administrative terms & conditions for
frequency of submission. When the FFR is due on
or before 9/30, then the reporting period is from
project's start date to 6/30. When the FFR is due
on or before 12/30, then the reporting period is
from project's start date to 9/30. FFRs are
submitted each calendar year via email to
rtpfc-grants@epa.gov.
Due 10/30 by each reporting
year
Required if cumulative total of grant
budget under Equipment, Supplies,
Contractual & Other (subawards)
exceeds $250,000 threshold.
See programmatic terms
and conditions for
frequency of submission.
EPA grants contain General, Administrative, and Programmatic terms and conditions which typically include reporting
requirements such as filing an interim (annual) Federal Financial Report (FFR), annual MBE/WBE Report (if applicable),
submitting progress reports. Additional terms and conditions may also be specified in an individual award document
based on the project or recipient. Recipients should regularly review the terms and conditions throughout the duration
of projects to ensure compliance with all requirements General (based on statutory or national requirements),
Administrative (based on regulations or policies), or Programmatic (based on specific requirements imposed by the EPA
program office, such as the timing and content of progress reports).
42
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The EPA Grant Award
Grant Acceptance
Once EPA selects a grant application for award, it prepares an award agreement that is signed by the EPA Award Official.
The award agreement is then sent to the applicant, generally via e-mail. EPA expects recipients to review the award
agreement and the terms and conditions, to confirm that the applicant concurs with all the information.
Key Points to Review in the EPA Grant Award
1. Recipient Information: Is the recipient name, payee and recipient project manager information
correct?
2. Grant Project Title & Explanation of Changes: Is the information regarding the description
of the grant, the budget and project period start and end dates, including the total budget and project period cost
correct?
3. Notice of Award: Is the amount of federal funding award and cost-share information (if applicable)
correct?
4. EPA Funding Information Table: Are the amounts listed in the EPA amount funded (prior and this
action), EPA in-kind amount, Recipient/State/Local/Other contributions correct?
5. Table A Object Class Category: Are the amounts listed in the Budget Summary Page, the Indirect
Cost, Total Share information by Recipient and EPA, Total Approved Assistance Amount, Program Income, Total
EPA Amount Awarded This Action and Total EPA Amount Awarded to Date correct?
6. Administrative Terms & Conditions: Will the grant require annual submission of an FFR,
MBE/WBE or Subaward reporting?
7. Programmatic Conditions: How often should progress reports be submitted?
8. Note: In addition to the Administrative and Programmatic terms and conditions in the EPA Grant Award,
review all "Electronic Administrative/Programmatic Terms and Conditions;" links provided in the award.
A sample of an EPA grant award document follows after this page.
i
i
i
i
i
i
i
i
\
\
21 calendar
days
If the recipient disagrees with the terms and
conditions specified in the award, the
recipient must furnish a notice of
disagreement to the EPA Award Official
within 21 calendar days from the EPA award
mailing date via Region 9's
dedicated email address,
GrantsRegion9@epa.gov.
\
i
i
i
i
i
i
i
i
ACCEPTANCE WITHIN 21 DAYS
The recipient accepts the grant by:
¦ Drawing down EPA funds; or
¦ Raising no objections to the award agreement within
21 days of receipt of the award agreement and make
no drawdowns.
If the recipient has not raised any objections after 21
days. EPA considers the award agreement to be
accepted regardless of whetherthe recipient draws
down funds.
43
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F - 9T033320- 0 Page 1
\
o
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EPA Funding Information
F - 9T033320 - 0 Page 2
FUNDS
FORMER AWARD
THIS ACTION
AMENDED TOTAL
EPA Amount This Action
$
$ 945,000
$ 945,000
EPA In-Kind Amount
$
$
$0
Unexpended Prior Year Balance
$
$
$0
Other Federal Funds
$
$
$0
Recipient Contribution
$
$315,000
$315,000
State Contribution
$
$
$0
Local Contribution
$
$
$0
Other Contribution
$
$
$0
Allowable Project Cost
$0
$ 1,260,000
$ 1,260,000
Assistance Program (CFDA)
Statutory Authority
Reyuldluiy Aulliunly
66.432 - State Public Water System Supervision
Safe Drinking Water Act: Sec. 1443(a)
2 CFR 200
2CFR1500
40 CFR 33 and 40 CFR 35 Subpart A
F i^ucil
Site Name
Req No
FY
Approp.
Code
Budget
Organization
PRC
Object
Class
Site/Project
Cost
Organization
Obligation /
Deobligation
1909W41004
19
E1
09L3
000B03
4118
945,000
945,000
45
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F-9T033320-0 Page 3
Budget Summary Page
Table A - Object Class Category
(Non-construction)
Total Approved Allowable
Budget Period Cost
1. Personnel
$510,400
2. Fringe Benefits
$299,600
3. Travel
$0
4. Equipment
$0
5. Supplies
$122,130
6. Contractual
$152,114
7. Construction
$0
8. Other
$5,000
9. Total Direct Charges
$1,089,244
10. Indirect Costs: 20.30% Base MTDC
$170,756
11. Total (Share: Recipient 25.00 % Federal 75.00 %.)
$1,260,000
12. Total Approved Assistance Amount
$945,000
13. Program Income
$0
14. Total EPA Amount Awarded This Action
$945,000
15. Total EPA Amount Awarded To Date
$945,000
46
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F - 9T033320 - 0 Page 4
Administrative Conditions
General Terms and Conditions
The recipient agrees to comply with the current EPA general terms and conditions available at:
https://www.epa.qov/qrants/epa-qeneral-terms-and-conditions-effective-november-12-2020-or-later.
These terms and conditions are in addition to the assurances and certifications made as a part of the award and
the terms, conditions, or restrictions cited throughout the award.
The EPA repository for the general terms and conditions by year can be found at:
http://www.epa.oov/orants/qrant-terms-and-conditionshttps://www.epa.oov/orants/qrant-terms-and-conditions.
A. Federal Financial Reporting (FFR)
For awards with cumulative project and budget periods greater than 12 months, the recipient will submit an
annual FFR (SF 425) covering the period from "project/budget period start date" to September 30 of each
calendar year to the EPA Finance Center in Research Triangle Park, NC. The FFR will be submitted
electronically to rtpfc-arants@epa.gov no later than December 30 of the same calendar year.
B. Procurement
The recipient will ensure all procurement transactions will be conducted in a manner providing full and open
competition consistent with 2 CFR Part 200.319. In accordance 2 CFR Part 200.323 the grantee and
subgrantee(s) must perform a cost or price analysis in connection with applicable procurement actions, including
contract modifications.
State recipients must follow procurement procedures as outlined in 2 CFR Part 200.317.
C. Six Good Faith Efforts 40 CFR § 33, Subpart C /Contract Provisions /Bidders List
Pursuant to 40 CFR § 33.301, the recipient agrees to make the following good faith efforts whenever procuring
construction, equipment, services and supplies under an EPA financial assistance agreement, and to require that
sub-recipients, loan recipients, and prime contractors also comply. Records documenting compliance with the six
good faith efforts shall be retained:
(a) Ensure DBEs are made aware of contracting opportunities to the fullest extent practicable through
outreach and recruitment activities. For Indian Tribal, State and Local and Government recipients, this will
include placing DBEs on solicitation lists and soliciting them whenever they are potential sources.
(b) Make information on forthcoming opportunities available to DBEs and arrange time frames for contracts
and establish delivery schedules, where the requirements permit, in a way that encourages and facilitates
participation by DBEs in the competitive process. This includes, whenever possible, posting solicitations for
bids or proposals for a minimum of 30 calendar days before the bid or proposal closing date.
(c) Consider in the contracting process whether firms competing for large contracts could subcontract with
DBEs. For Indian Tribal, State and local Government recipients, this will include dividing total requirements
when economically feasible into smaller tasks or quantities to permit maximum participation by DBEs in the
competitive process.
(d) Encourage contracting with a consortium of DBEs when a contract is too large for one of these firms to
handle individually.
(e) Use the services and assistance of the SBA and the Minority Business Development Agency of the
Department of Commerce.
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(f) If the prime contractor awards subcontracts, require the prime contractor to take the steps in paragraphs
(a) through (e) of this section.
CONTRACT ADMINISTRATION PROVISIONS, 40 CFR § 33.302
The recipient agrees to comply with the contract administration provisions of 40 CFR § 33.302 (a)-(d) and (i).
BIDDERS LIST, 40 CFR § 33.501(b) and (c)
Recipients of a Continuing Environmental Program Grant or other annual reporting grant, agree to create and
maintain a bidders list. Recipients of an EPA financial assistance agreement to capitalize a revolving loan fund
also agree to require entities receiving identified loans to create and maintain a bidders list if the recipient of the
loan is subject to, or chooses to follow, competitive bidding requirements. Please see 40 CFR § 33.501 (b) and (c)
for specific requirements and exemptions.
D. Disadvantaged Business Enterprise (DBEs) - UTILIZATION OF SMALL, MINORITY AND WOMEN'S
BUSINESS ENTERPRISES
GENERAL COMPLIANCE, 40 CFR Part 33
The recipient agrees to comply with the requirements of EPA's Disadvantaged Business Enterprise (DBE)
Program for procurement activities under assistance agreements, contained in 40 CFR Part 33 except as
described below based upon the associated class deviation.
EPA MBE/WBE CERTIFICATION, 40 CFR Part 33, Subpart B
A class exception to the following provisions of Subpart B of 40 CFR Part 33 has been issued suspending the
EPA MBE/WBE certification program: §33.204(a)(3) providing that an entity may apply to EPA MBE or WBE
certification after unsuccessfully attempting to obtain certification as otherwise described in §33.204; and §33.205
through and including §33.211. The class exception was authorized pursuant to the authority in 2 CFR
§1500.3(b).
FAIR SHARE OBJECTIVES, 40 CFR Part 33, Subpart D
A class exception to the entire Subpart D of 40 CFR Part 33 has been authorized pursuant to the authority in 2
CFR §1500.3(b). Notwithstanding Subpart D of 40 CFR Part 33, recipients are not required to negotiate or apply
fair share objectives in procurements under assistance agreements.
E. MBE/WBE Reporting
General Compliance, 40 CFR Part 33, Subpart E - Reporting Condition
This award meets the conditions below and, henceforth, is subject to Disadvantaged Business Enterprise (DBE)
Program reporting requirements based on EPA's review of the planned budget. Conversely, the recipient must
submit to the GrantsReaion9@epa.gov a justification and budget detail within 21 days of the award date
demonstrating that this award is not subject to the DBE reporting requirements.
MBE/WBE reports from grantees are required annually for assistance agreements where there are funds
budgeted for procuring construction, equipment, services and supplies, including funds budgeted for direct
procurement by the recipient or procurement under subawards or loans in the "Other" category, that exceed the
Simplified Acquisition Threshold as defined by the Federal Acquisition Regulation (currently set at $250,000),
including amendments and/or modifications.
The recipient agrees to complete and submit a "MBE/WBE Utilization under Federal Grants. Cooperative
agreements" report (EPA Form 5700-52A') on an annual basis. All procurement actions that are reportable, not
just that portion which exceeds the Simplified Acquisition Threshold.
When completing the annual report, recipients are instructed to check the box titled "annual:" in section 1B of the
form. For the final report, recipients must check the box indicated for the "last report" of the project in section 1B
of the form. Annual reports are due by October 30th of each year. Final reports are due by October 30th or 90
days after the end of the project period, whichever comes first.
48
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The reporting requirement is based on total procurements. Recipients with expended and/or budgeted funds for
procurement are required to report annually whether the planned procurements take place during the reporting
period or not. If no budgeted procurements take place during the reporting period, the recipient should check the
box in section 5B when completing the form.
MBE/WBE reports should be sent to GrantsReqion9@epa.qov and assigned EPA Grants Specialist. The current
EPA Form 5700-52A is located at https://www.epa.qov/qrants/epa-form-5700-52a-united-states-environmental-
protection-aqencv-minoritv-business.
This provision represents an approved deviation from the MBE/WBE reporting requirements as described in 40
CFR, Part 33, Section 33.502.
Programmatic Conditions
a]. Performance Reporting and Final Performance Report
Performance Reports - Content
In accordance with 2 CFR 200.328, 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 why established
outputs/outcomes were not met; and 3) Additional pertinent information, including, when appropriate, analysis and
explanation of cost overruns or high-unit costs.
The recipient agrees to inform EPA as soon as problems, delays, or adverse conditions which will materially
impair the ability to meet the outputs/outcomes specified in the assistance agreement work plan are known.
For State Categorical Program Grants Only: Interim performance and final progress reports must prominently
display the three Essential Elements for state work plans: 1) Strategic Plan Goal; (2) Strategic Plan Objective;
and (3) Workplan Commitments plus time frame.
Performance Reports - Frequency
The recipient agrees to submit semi-annual performance reports electronically to the EPA Project Officer within
30 days after each reporting period ends (see workplan for specific dates). The final report is due 90 days after
the end of the project period.
b]. Cybersecurity
(a) The recipient agrees that when collecting and managing environmental data under this assistance
agreement, it will protect the data by following all applicable State law cybersecurity requirements.
(b) (1) EPA must ensure that any connections between the recipient's network or information system and
EPA networks used by the recipient to transfer data under this agreement, are secure. For purposes of this
Section, a connection is defined as a dedicated persistent interface between an Agency IT system and an
external IT system for the purpose of transferring information. Transitory, user-controlled connections such as
website browsing are excluded from this definition.
If the recipient's connections as defined above do not go through the Environmental Information Exchange
Network or EPA's Central Data Exchange, the recipient agrees to contact the EPA Project Officer (PO) and work
with the designated Regional/Headquarters Information Security Officer to ensure that the connections meet EPA
security requirements, including entering into Interconnection Service Agreements as appropriate. This condition
does not apply to manual entry of data by the recipient into systems operated and used by EPA's regulatory
programs for the submission of reporting and/or compliance data.
(b)(2) The recipient agrees that any subawards it makes under this agreement will require the
subrecipient to comply with the requirements in (b)(1) if the subrecipient's network or information system is
connected to EPA networks to transfer data to the Agency using systems other than the Environmental
49
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Information Exchange Network or EPA's Central Data Exchange. The recipient will be in compliance with this
condition: by including this requirement in subaward agreements; and during subrecipient monitoring deemed
necessary by the recipient under 2 CFR 200.331 (d), by inquiring whether the subrecipient has contacted the EPA
Project Officer. Nothing in this condition requires the recipient to contact the EPA Project Officer on behalf of a
subrecipient or to be involved in the negotiation of an Interconnection Service Agreement between the
subrecipient and EPA.
c]. Quality Assurance
In accordance with 2 CFR 1500.11, the recipient must develop and implement quality assurance and quality
control procedures, specifications and documentation that are sufficient to produce data of adequate quality to
meet project objectives. Recipients implementing environmental programs within the scope of the assistance
agreement must submit to the EPA Project Officer an approvable Quality Assurance Project Plan (QAPP) at least
60 days prior to the initiating of data collection or data compilation. The Quality Assurance Project Plan (QAPP) is
the document that provides comprehensive details about the quality assurance, quality control, and technical
activities that must be implemented to ensure that project objectives are met. Environmental programs include
direct measurements or data generation, environmental modeling, compilation of date from literature or electronic
media, and data supporting the design, construction, and operation of environmental technology.
The QAPP should be prepared in accordance with EPA QA/R-5: EPA Requirements for Quality Assurance
Project Plans.
No environmental data collection or data compilation may occur until the QAPP is approved by the EPA Project
Officer and Quality Assurance Regional Manager. When the recipient is delegating the responsibility for an
environmental data collection or data compilation activity to another organization, the EPA Regional Quality
Assurance Manager may allow the recipient to review and approve that organization's QAPP. Contact the Region
9 QA Office at 415-972-3431.
d]. Competency of Organizations Generating Environmental Measurement Data
Following EPA Policy Directive Number FEM-2012-02, recipient agrees to demonstrate competency of any
laboratory carrying out any activities involving the generation of environmental data on its behalf. Laboratory
competency shall be maintained for the duration of the project period of this agreement and documented during
the annual reporting process. A copy of the Policy is available online at https://www.epa.gov/measurements-
modelinq
### END OF DOCUMENT ###
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Grant Payments
Proper Payment Drawdown
As required by 2 CFR 200305(b), EPA now requires that recipients of
EPA financial assistance participate in the Automated Standard
Application for Payments (ASAP) system. Recipients must only draw
funds for the minimum amounts needed for actual and immediate cash
requirements to pay employees, contractors, subrecipients or to satisfy
other obligations for allowable costs under the assistance agreement.
The timing and amounts of the drawdowns must be as close as
administratively feasible to actual disbursement of EPA funds.
Disbursement within 5 business days of the drawdown will materially
comply with this requirement. Excess funds drawdown not meeting
this requirement should be returned to EPA. If a recipient draws down
funds in excess of the allowed amount, the recipient must contact
EPA's Research Triangle Park Finance Center at rtpfc-grantsPepa.qoy
for instructions on how to return the funds to EPA. Note that enrolling
in ASAP provides recipients with access to their funds even if EPA is not
fully operating due to a lapse of EPA appropriations or EPA financial
system upgrades and recipients must continue to comply with the 5-
business day disbursement requirement in these situations. Unless a
waiver has been approved by EPA, all recipients must be enrolled or
enroll in ASAP to receive payments.
To enroll in ASAP, please complete the ASAP Initiate Enrollment
Form and email it to rtpfc-grants@epa.qov. Once enrolled, recipients
can access ASAP at www.asap.gov to request payments. The ASAP
payment process is designed to provide federal funds to a recipient
organization within 48 hours.
INSTRUCTIONS FOR MAKING PAYMENTS OR RETURNING FUNDS
Instructions on how to make a payment to EPA/Returning funds to EPA are located at:
https://www.epa.Rov/financial. Further information on various types of payments can also be found at this link.
21 CALENDAR DAYS
The recipient accepts conditions of the award
agreement by drawing down funding. If the
recipient disagrees with the terms and
conditions or do not wish to accept EPA
funding, the authorized representative must
send a notice of disagreement to the EPA
Award Official within 21 days of the award
mailing date through EPA Region 9's email
address: GrantsReaion9@eDa.gov
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RAIN-2018-G06
EPA Requirements for Enrolling in the Automated Standard Application for Payments (ASAP)
System and Disbursing EPA Funds Within 5 business Days of Drawdown
Notification Date: September 21, 2018
Purpose: This Recipient/Applicant Information Notice (RAIN) informs recipients and applicants
of EPA's policy regarding the use of the ASAP system and disbursing funds promptly.
Summary: EPA now requires that recipients of EPA financial assistance participate in the
Automated Standard Application for Payments (ASAP) system. EPA also requires that
recipients (other than states) disburse substantially all funds within 5 business days of drawing
down the funds from EPA.1 Recipients may not retain more than 5% of the amount drawn down,
or $1,000 whichever is less, 5 business days after drawdown to materially comply with the
standard. If a recipient draws down funds in excess of the allowed amount, the recipient must
contact EPA's Research Triangle Park Finance Office at rtpfc-grants@epa.gov for instructions
on whether to return the funds to EPA. Note that enrolling in ASAP provides recipients with
access to their funds even if EPA is not fully operating due to a lapse of EPA appropriations or
EPA financial system upgrades and recipients must continue to comply with the 5-business day
disbursement requirement in these situations.
Both policy requirements are implemented in EPA's General Terms and Conditions for new
awards as well as supplemental and incremental funding actions on or after October 1, 2018.
This requirement does not apply to no-cost actions, direct stipend payments to Fellows under 40
CFR 46.200(b), or to recipients exempt from electronic funds transfer payment requirements
under 31 CFR 208.4.
Applicants or recipients who cannot satisfy one or both requirements may request exceptions to
these requirements prior to or after award if they demonstrate that compliance will impose undue
administrative or financial management burdens on the recipient or that granting the waiver is
otherwise in the public interest.
The exceptions, if granted, will be effective for the life of the assistance agreement(s) covered by
the request and may be subject to conditions. To request an exception, please see the Exception
Instructions below.
Background: Over 95% of EPA financial assistance recipients are currently enrolled in ASAP -
EPA's preferred payment mechanism since 1998. This payment method provides faster
distribution of funds and allows recipients to more easily track funds than the manual Automated
Clearing House (ACH) Payment method. Recipients enrolled in ASAP may be able to
drawdown approved funds when EPA is making upgrades to financial management systems or
during lapses of EPA appropriations. Recipients using the ACH or other payment systems are
1 For the purposes of this policy, the term "state" includes any state of the United States, the District of Columbia,
the Commonwealth of Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, the Commonwealth of the
Northern Mariana Islands, and any agency or instrumentality thereof exclusive of local governments.
1
52
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unable to drawdown funds electronically in these situations and must make alternate
arrangements that are burdensome for both recipients and EPA.
While the regulations at 2 CFR 200.305(b) require that recipients minimize the time elapsing
between drawing down EPA funds and disbursing the funds for allowable costs, there have been
misunderstandings about this requirement in the context of audits and other reviews. EPA
actions to recover funds that were not disbursed in a timely manner can adversely impact
recipients. EPA policy sets a nationally consistent 5 business day disbursement standard.
Policy Exception Instructions
Applicants or recipients may request exceptions to the ASAP enrollment or 5-business day from
drawdown disbursement requirements described in EPA's General Terms and Conditions if they
demonstrate that compliance places an undue administrative or financial management burden or
EPA determines that granting the exception is in the public interest.
The exceptions, if granted, will be effective for the life of the assistance agreement(s) covered by
the request and may be subject to conditions. Exception requests must be submitted in writing to
the National Policy, Training and Compliance Division of EPA's Office of Grants and
Debarment (OGD) at OGDWaivers@epa.gov. The email subject should be "ASAP
Requirements Exception Request" or "5 Business Day Disbursement Exception Request,"
depending on the nature of the request, and the body of the email must include the following
information:
• Funding Opportunity Number (FON) (if available)
• Organization Name and DUNS/Universal Identifier
• Organization's Contact information
• Explanation of the inability of the organization to utilize the Automated Standard
Application for Payments (ASAP) system and/or to disburse EPA funds within 5 business
days
OGD will generally respond to the request in writing within 15 calendar days of receipt although
a longer response time may be necessary depending on the complexity of the matter and staffing
considerations. If the ASAP Policy Waiver Request and/or 5 Business Day Disbursement Policy
Waiver Request is granted, the applicant will receive documentation that their waiver is
approved and that it applies to the life of the EPA assistance agreement. The applicant should
maintain a copy of the waiver approval in their official grant file.
2
53
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Timekeeping
The recipient's personnel payroll and records system must be capable of providing reports on the activities of each employee who
works directly on a grant. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work
performed.
Activity reports are typically signed by the individual employee and/or by a responsible supervisory official having first-hand
knowledge of the activities performed by an employee. The supervisor should be able to certify that the distribution of activity
represents a reasonable estimate of the actual work performed by the employee during the periods covered by the reports. Reports
are typically prepared at least monthly and must coincide with one or more pay periods.
Managing Payroll Information
Recipients are encouraged to use timesheets or personnel activity reports as a best practice but does not require
them if the recipient's payroll system provides adequate support for charging personnel costs to EPA grants.
Reports must also reflect an after-the-fact determination of the actual activity of each employee.
Recipients are responsible for ensuring that payroll costs are reasonable. In general, this responsibility means that
the salaries and wages paid for work on the grant must be consistent with what the recipient's organization pays
for similar work under other projects.
Payroll Records Must:
¦ Be supported by a system of internal controls that provides reasonable assurance that the charges
are accurate, allowable and properly allocated.
¦ Be incorporated into the organization's official documentation.
¦ Reasonably reflect the total activity for which an employee is compensated.
¦ Encompass both federally-assisted and all other activities compensated by the organization on an
integrated basis.
¦ Comply with the organization's established accounting policies and practices.
2 CFR 200 Code of Federal
Regulations
§200.430 Compensation—personal
services.
In-depth
Information on
How to Record and
Charge Payroll
Costs
$
54
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The Federal Financial Report (Standard Form 425)
The Federal Financial Report (FFR) is a reporting requirement throughout the grant's lifecycle. The submission of
annual/interim FFR is on an annual basis as directed by the terms and conditions of the grant agreement. The following
reporting period end dates shall be used for the annual/interim reports: 9/30 (reporting period of 07/01-06/30) or 12/31
(reporting period of 10/01-09/30). Separately, the final FFR must be submitted at project completion to EPA's Research
Triangle Park Finance Center (RTPFC) via email no later than 90 calendar days (120 days for grants awarded after
11/12/2020) after the project period end date.
Filing the Federal Financial Report
Grant recipients must complete and submit to EPA's Research Triangle Park Finance Office (RTPFC) the FFR which is used
to report on the financial progress of grants. The frequency of submitting the FFR is specified in the grant terms and
conditions.
Where to Send Annual & Final FFRs:
Calling RTP Finance Center:
Download the FFR form (SF 425):
rtpfc-grantsffiepa.gov
8:00 am - 5:00 pm EST
(919) 541-5288 (subject to updating)
https://www.epa.gov/grants/epa-grantee-forms
The next pages present a snapshot of the Standard Form 425 and the numbered sections corresponding to required fields
and the instructions.
The SF 425 require recipients to
disclose information about:
¦ Federal funds authorized & expended
¦ Cost share or matching funds required
from recipients during the reporting
period*
¦ Program Income*
¦ Indirect cost expenditures
* To determine applicability, the recipient's EPA
Award Document on page 3, "Budget Summary
Table," will have this information.
120 days
Recipients must submit a final FFR no later
than 120 days after a grant has ended.
55
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View Burden Statement
Federal Financial Report
(Follow form Instructions)
OMB Number: 4040-0014
Expiration Date: 02/28/2022
1. Federal Agency and Organizational Element to Which Report is Submitted
2. Federal Grant or Other Identifying Number Assigned by Federal
Agency (To report multiple grants, use FFR Attachment)
3. Recipient Organization (Name and complete address including Zip code)
Recipient Organization Name: |
Street"!:
Street2:
City:
State:
Country:
"1 County:
Province:
USA: UNITED STATES
ZIP / Postal Code:
4a. DUNS Number
4a I
4b. EIN
4b i
5. Recipient Account Number or Identifying Number
(To report multiple grants, use FFR Attachment)
6. Report Type
| | Quarterly
| | Semi-Annual
| | Annual
| | Final
7. Basis of Accounting
| | Cash
~ Accrual
8. Project/Grant Period
From: Q To'
I-
9. Reporting Period End Date
10. Transactions
Cumulative
(Use lines a-c for single or multiple grant reporting)
Federal Cash (To report multiple grants, also use FFR attachment):skipthis section; not required by EPA
a. Cash Receipts
SKIP SECTIQ
NS
o.oc
b. Cash Disbursements
10 a-c. NOT HE QUIRED BY
o.oc
c. Cash on Hand (line a minus b)
EPA.
o.oc
(Use lines d-o for single grant reporting)
Federal Expenditures and Unobligated Balance:
d. Total Federal funds authorized d: Total amount awarded
irOdr
e Federal share of expenditures e: Total amount expended and paid out from recipient's accounting system
oo
f. Federal share of unliquidated obligations f: °n <^ ^isj.ar® Federal portion of unliquidated obligations incurred, but not yet
2 _ whmh innli irfes riirart inrlirBrt fivpfinsfis anrl amm ints rli ib mrrtrarfnre nr si ihawarrfe
| laid 01
[ha
charged to the awarc
iral sham nf
lEdei
g. Total Federal share (sum of lines e and f) unliquidated obligations must be ZERO for the final FFR. g: if the Total Federal Shs e (Lin 3 g) is less than the
lOf
amount you received throi jhthe
then vou will be required tc repay
ASAF system,
the excess
h. Unobligated balance of Federal Funds (line d minus g) h: The Unobligated Balance of
oo
Federal Funds is Ihe arnouril EPA will
de-oliaate from the award.
Recipient Share:
JJH
amount.
i. Total recipient share required
10i: Refer to EPA Award Document, page 3 Budget Summary Table if recipient cost share
ipplie:.
oc
Recipient share of expenditures
oc
k. Remaining recipient share to be provided (line i minus j)
oc
Program Income:
m
101: Refer to EPA award document, page 3 "Budget Summary" if program income applies.
I. Total Federal program income earned
oo
m. Program Income expended in accordance with the deduction alternative
oo
n. Program Income expended in accordance with the addition alternative
oo
o. Unexpended program income (line I minus line m or line n)
0.00
56
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11. Indirect Expense
e. Amount
Charged
a. Type
b. Rate
c. Period From Period To
d. Base
f. Federal Share
g. Totals:
12. Remarks: Attach any explanations deemed necessary or information required by Federal sponsoring agency in compliance with governing legislation:
Add Attachment
Delete Attachment
View Attachment
13. Certification: By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the
expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I
am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or
administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730
and 3801-3812).
a. Name and Title of Authorized Certifying Official
First Name: p
Prefix:
13a
Last Name: |~
Title:
~| Middle Name:
| Suffix:
b. Signature of Authorized Certifying Official
d. Email Address
13d
c. Telephone (Area code, number and extension)
' 11 13c
e. Date Report Submitted
I 1
14. Agency use only:
Standard Form 425
57
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Federal Financial Report Instructions
Report Submissions
1) Recipients will be instructed by Federal agencies to submit the Federal Financial Report (FFR) to
a single location, except when an automated payment management reporting system is utilized. In
this case, a second submission location may be required by the agency.
2) If recipients need more space to support their FFRs, or FFR Attachments, they should provide
supplemental pages. These additional pages must indicate the following information at the top of
each page: Federal grant or other identifying number (if reporting on a single award), recipient
organization, Data Universal Numbering System (DUNS) number, Employer Identification Number
(EIN), and period covered by the report.
Reporting Requirements
1) The submission of interim FFRs will be on a quarterly, semi-annual, or annual basis, as directed by
the Federal agency. A final FFR shall be submitted at the completion of the award agreement. The
following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31.
For final FFRs, the reporting period end date shall be the end date of the project or grant period.
2) Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of
each reporting period. Annual reports shall be submitted no later than 90 days after the end of each
reporting period. Final reports shall be submitted no later than 90 days after the project or grant
period end date.
Note: For single award reporting:
1) Federal agencies may require both cash management information on lines 10(a) through 10(c) and
financial status information lines 10(d) through 10(o).
2) 10(b) and 10(e) may not be the same until the final report.
Line Item Instructions for the Federal Financial Report
FFR
Number
Reporting Item
Instructions
Cover Information
1
Federal Agency and
Organizational Element to
Enter the name of the Federal agency and organizational element
identified in the award document or as instructed by the agency.
Which Report is Submitted
2
Federal Grant or Other
Identifying Number
Assigned by Federal
For a single award, enter the grant number assigned to the award by the
Federal agency. For multiple awards, report this information on the FFR
Attachment. Do not complete this box if reporting on multiple awards.
Agency
3
Recipient Organization
Enter the name and complete address of the recipient organization
including zip code.
4a
DUNS Number
Enter the recipient organization's Data Universal Numbering System
(DUNS) number or Central Contract Registry extended DUNS number.
4b
EIN
Enter the recipient organization's Employer Identification Number (EIN).
5
Recipient Account Number
or Identifying Number
Enter the account number or any other identifying number assigned by the
recipient to the award. This number is for the recipient's use only and is
not required by the Federal agency. For multiple awards, report this
58
Revised 6/28/2010
-------
FFR
Number
Reporting Item
Instructions
information on the FFR Attachment. Do not complete this box if
reporting on multiple awards.
6
Report Type
Mark appropriate box. Do not complete this box if reporting on multiple
awards.
7
Basis of Accounting
(Cash/Accrual)
Specify whether a cash or accrual basis was used for recording
transactions related to the award(s) and for preparing this FFR. Accrual
basis of accounting refers to the accounting method in which expenses are
recorded when incurred. For cash basis accounting, expenses are
recorded when they are paid.
8
Project/Grant Period,
From: (Month, Day, Year)
Indicate the period established in the award document during which
Federal sponsorship begins and ends.
Note: Some agencies award multi-year grants for a project period that is
funded in increments or budget periods (typically annual increments).
Throughout the project period, agencies often require cumulative
reporting for consecutive budget periods. Under these circumstances,
enter the beginning and ending dates of the project period not the budget
period.
Do not complete this line if reporting on multiple awards.
Project/Grant Period, To:
See the above instructions for "Project/Grant Period, From: (Month, Day,
(Month, Day, Year)
Year)."
9
Reporting Period End
Date: (Month, Day, Year)
Enter the ending date of the reporting period. For quarterly, semi-annual,
and annual interim reports, use the following reporting period end dates:
3/31, 6/30, 9/30, or 12/31. For final FFRs, the reporting period end date
shall be the end date of the project or grant period.
10
Transactions
Enter cumulative amounts from date of the inception of the award through the end date of the
reporting period specified in line 9.
Use Lines 10a through 10c, Lines lOd through lOo, or Lines 10a through lOo, as specified by the
Federal agency, when reporting on single grants.
Use Line 12, Remarks, to provide any information deemed necessary to support or explain FFR data.
Federal Cash (To report multiple grants, also use FFR Attachment)
10a
Cash Receipts
Enter the cumulative amount of actual cash received from the Federal
agency as of the reporting period end date.
10b
Cash Disbursements
Enter the cumulative amount of Federal fund disbursements (such as cash
or checks) as of the reporting period end date. Disbursements are the sum
of actual cash disbursements for direct charges for goods and services, the
amount of indirect expenses charged to the award, and the amount of cash
advances and payments made to subrecipients and contractors.
For multiple grants, report each grant separately on the FFR Attachment.
The sum of the cumulative cash disbursements on the FFR Attachment
must equal the amount entered on Line 10b, FFR.
10c
Cash On Hand (Line 10a
Enter the amount of Line 10a minus Line 10b. This amount represents
Minus Line 10b)
immediate cash needs. If more than three business days of cash are on
hand, the Federal agency may require an explanation
59
Revised 6/28/2010
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FFR
Number
Reporting Item
Instructions
on Line 12, Remarks, explaining why the drawdown was made
prematurely or other reasons for the excess cash.
Federal Expenditures and Unobligated Balance: Do not complete this section if reporting on multiple
awards.
lOd
Total Federal Funds
Enter the total Federal funds authorized as of the reporting period end
Authorized
date.
lOe
Federal Share of
Expenditures
Enter the amount of Federal fund expenditures. For reports prepared on a
cash basis, expenditures are the sum of cash disbursements for direct
charges for property and services; the amount of indirect expense charged;
and the amount of cash advance payments and payments made to
subrecipients. For reports prepared on an accrual basis, expenditures are
the sum of cash disbursements for direct charges for property and services;
the amount of indirect expense incurred; and the net increase or decrease
in the amounts owed by the recipient for (1) goods and other property
received; (2) services performed by employees, contractors, subrecipients,
and other payees; and (3) programs for which no current services or
performance are required. Do not include program income expended in
accordance with the deduction alternative, rebates, refunds, or other
credits. (Program income expended in accordance with the deduction
alternative should be reported separately on Line lOo.)
lOf
Federal Share of
Unliquidated Obligations
Unliquidated obligations on a cash basis are obligations incurred, but not
yet paid. On an accrual basis, they are obligations incurred, but for which
an expenditure has not yet been recorded. Enter the Federal portion of
unliquidated obligations. Those obligations include direct and indirect
expenses incurred but not yet paid or charged to the award, including
amounts due to subrecipients and contractors. On the final report, this line
should be zero unless the awarding agency has provided other
instructions.
Do not include any amount in Line 1 Of that has been reported in Line lOe.
Do not include any amount in Line 1 Offor a future commitment offunds
(such as a long-term contract) for which an obligation or expense has not
been incurred.
10g
Total Federal Share (Sum
Enter the sum of Lines lOe and lOf.
of Lines lOe and lOf)
lOh
Unobligated Balance of
Enter the amount of Line lOd minus Line lOg.
Federal Funds (Line lOd
Minus Line lOg)
Recipient Share: Do not complete t
lis section if reporting on multiple awards.
lOi
Total Recipient Share
Required
Enter the total required recipient share for reporting period specified in
line 9. The required recipient share should include all matching and cost
sharing provided by recipients and third-party providers to meet the level
required by the Federal agency. This amount should not include cost
sharing and match amounts in excess of the amount required by the
Federal agency (for example, cost overruns for which the recipient incurs
additional expenses and, therefore, contributes a greater level of cost
60
Revised 6/28/2010
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FFR
Number
Reporting Item
Instructions
sharing or match than the level required by the Federal agency).
10j
Recipient Share of
Expenditures
Enter the recipient share of actual cash disbursements or outlays (less any
rebates, refunds, or other credits) including payments to subrecipients and
contractors. This amount may include the value of allowable third party
in-kind contributions and recipient share of program income used to
finance the non-Federal share of the project or program. Note: On the
final report this line should be equal to or greater than the amount of Line
lOi.
10k
Remaining Recipient Share
to be Provided (Line lOi
Enter the amount of Line lOi minus Line lOj. If recipient share in Line
lOj is greater than the required match amount in Line lOi, enter zero.
Minus Line lOi)
Program Income: Do not complete this section if reporting on multiple awards.
101
Total Federal Program
Income Earned
Enter the amount of Federal program income earned. Do not report any
program income here that is being allocated as part of the recipient's cost
sharing amount included in LinelOj.
10m
Program Income Expended
Enter the amount of program income that was used to reduce the Federal
in Accordance With the
share of the total project costs.
Deduction Alternative
lOn
Program Income Expended
Enter the amount of program income that was added to funds committed
in Accordance With the
to the total project costs and expended to further eligible project or
Addition Alternative
program activities.
lOo
Unexpended Program
Income (Line 101 Minus
Line 10m or Line lOn)
Enter the amount of Line 101 minus Line 10m or Line lOn. This amount
equals the program income that has been earned but not expended, as of
the reporting period end date.
11
Indirect Expense: Complete this information only if required by the awarding agency. Enter
cumulative amounts from date of the inception of the award through the end date of the reporting
period specified in line 9.
11a
Type of Rate(s)
State whether indirect cost rate(s) is Provisional, Predetermined, Final, or
Fixed.
lib
Rate
Enter the indirect cost rate(s) in effect during the reporting period.
11c
Period From; Period To
Enter the beginning and ending effective dates for the rate(s).
lid
Base
Enter the amount of the base against which the rate(s) was applied.
lie
Amount Charged
Enter the amount of indirect costs charged during the time period
specified. (Multiply lib. x lid.)
llf
Federal Share
Enter the Federal share of the amount in lie.
Hg
Totals
Enter the totals for columns lid, lie, and llf.
Remarks, Certification, and Agency Use Only
12
Remarks
Enter any explanations or additional information required by the Federal
sponsoring agency including excess cash as stated in line 10c.
13a
Typed or Printed Name and
Enter the name and title of the authorized certifying official.
Title of Authorized
Certifying Official
13b
Signature of Authorized
The authorized certifying official must sign here.
Certifying Official
13c
Telephone (Area Code,
Enter the telephone number (including area code and extension) of the
Number and Extension)
individual listed in Line 13a.
13d
E-mail Address
Enter the e-mail address of the individual listed in Line 13 a.
61
Revised 6/28/2010
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FFR
Number
Reporting Item
Instructions
13e
Date Report Submitted
Enter the date the FFR is submitted to the Federal agency using the
(Month, Day, Year)
month, day, year format.
14
Agency Use Only
This section is reserved for Federal agency use.
62
Revised 6/28/2010
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Understanding the MBE/WBE Utilization Under Federal Grants
(EPA Form 5700-52A)
If more than $250,000 is budgeted for procuring supplies, equipment, construction or services, the grant agreement will
include a term and condition that requires the submission of the EPA Form 5700-52A MBE/WBE (Minority Business
Enterprise/Woman Business Enterprise Utilization Under Federal Grants and Cooperative Agreements.) The term and
condition will also be included if the $250,000 threshold includes subaward(s), too.
As specified in EPA's Disadvantaged Business Enterprises (DBE), recipients are required to consider qualified DBEs for
contract work under grant projects. Recipients use EPA Form 5700-52A to document their efforts.
Do I Need to Submit a
MBE/WBE Form as part of my
annual reporting
requirement?
If more than $250)000total
combined (both federal & cost share) is budgeted for
Supplies, Equipment, Contractual and Other (i.e.,
subawards)
If the grant meets the $250,000
threshold, what is the report due
date and email address for
submitting the MBE/WBE Form?
October 30th of each calendar
yearforthe life of the grant. Region 9 recipients must email
the MBE/WBE Form to:
grantsregion9@epa.gov
Get the MBE/WBE Form Here: EPA Form 5700-52A
L ¦
Recipients are required to make the following good faith efforts whenever procuring construction, equipment,
services, and supplies under an EPA financial assistance agreement. A Native American recipient or prime contractor
must follow the six good faith efforts only if doing so would not conflict with exiting Tribal or Federal law, including
but not limited to the Indian Self-Determination and Education Assistance Act.
1. Ensure DBEs are made aware of contracting opportunities to the fullest extent practicable through outreach
and recruitment activities. For Indian Tribal, State, and Local Government recipients, this will include placing
DBEs on solicitation lists and soliciting them whenever they are potential sources.
2. Make information on forthcoming opportunities available to DBEs, arrange time frames for contracts, and
establish delivery schedules, where the requirements permit, in a way that encourages and facilitates
63
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participation by DBEs in the competitive process. This includes, whenever possible, posting solicitations for
bids or proposals for a minimum of 30 calendar days before the bid or proposal closing date.
3. Consider in the contracting process whether firms competing for large contracts could subcontract with DBEs.
For Indian Tribal, State, and Local Government recipients, this will include dividing total requirements when
economically feasible into smaller tasks or quantities to permit maximum participation by DBEs in the
competitive process.
4. Encourage contracting with a consortium of DBEs when a contract is too large for one of these firms to
handle individually.
5. Use the services and assistance of the SBA and the Minority Business Development Agency of the Department
of Commerce.
6. If the prime contractor awards subcontracts, require the prime contractor to take the steps in items 1
through 5.
MORE INFORMATION
ABOUT MBE/WBE and
DISADVANTAGED
BUSINESS ENTERPRISES
(DBEs)
Information regarding MBE/WBE and Accessing the Form:
https://www.epa.gov/grants/epa-form-5700-52a-united-states-environmental-
protection-aRency-minority-business
Participation by Disadvantaged Business Enterprises (DBEs) under EPA Programs (40
CFR § 33) & Contracting with small and minority businesses, women's business
enterprises, and labor surplus area firms (2 CFR § 200.321)
https://www.epa.gov/grants/disadvantaged-business-enterprise-program-under-epa-
assistance-aRreements-dbe-proRram
64
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Requesting Changes to a Grant Agreement
If changes to the grant agreement become necessary for the project to succeed, contact the EPA Project
Officer as soon as possible to discuss the changes. Be mindful that all changes must be within the scope of
the grant agreement and the majority of changes must be approved by EPA. Even if a change does not
specifically require approval by EPA, through regulation or the terms and conditions of the grant, it is good
practice to communicate changes to avoid potential pitfalls.
Submitting a Change
1 Depending on the complexity of changes to a grant agreement, different steps may be required
for the grant to comply with federal and EPA regulations. To request a change, submit to your EPA
Project Officer and Grants Specialist a written request (email), including a justification for the
proposed revisions.
1 Some types of changes require the prior approval of an authorized EPA official before they can be
implemented, while other changes can be implemented without EPA's approval, but still require
you to notify EPA. If changes to an award agreement are significant, a formal amendment may be
necessary.
A formal grant amendment is required for certain types of changes, i.e., increase of federal funds
and change in the budget/project period start and end dates. While other types of changes, such
as a rebudgeting request, requires a written notification to the EPA Project Officer, with the EPA
Grants Specialist copied to this request. The next pages provide various specific guidelines, along
with a sample of an email request for a rebudgeting request.
65
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Post Award Changes to Assistance Agreements
Requiring Prior Approval Under 2 CFR §200.308
APPLICABILITY
j FORMAL AMENDMENT
j PRIOR WRITTEN APPROVAL FROM EPA PROJECT
j NO PRIOR APPROVAL REQUIRED
! REQUIRED
! OFFICER
I (2 CFR §200.308)
! (2 CFR §200.308)
TRIBES
INTERTRIBAL
CONSORTIA OR
CONSORTIUM
STATES
LOCAL GOVERNMENTS
NONPROFITS
UNIVERSITIES
GRANT FUNDING:
Revisions which will result
in the need for additional
funding
GRANT EXTENSION:
Extend period of
performance or availability
of funds (no cost
extensions)
OTHER TYPES OF CHANGES
(for incorporation into
next formal amendment):
¦ Changes to terms &
conditions
¦ Changes in the scope
or objective of the
project with significant
budget revisions.
¦ Changes in the
approved cost
share/match provided.
¦ Preaward costs*
C!l Changes in key personnel, i.e., Principal
Investigator, Project Leader, Project Partner.
C!l Disengagement from the project for more
than 3 months or 25% reduction in time devoted
to the project by the approved Project Director
or Principal Investigator.
C!l Transfer of funds for inclusion of costs that
require prior approval (e.g., rebudget of funds to
the Equipment category for unapproved
equipment purchases; rebudget of funds for
indirect cost which was not previously included)
C!l Transfer of funds allotted for Training or
Conferences (Participant Support Costs)
C!l Transfer or contracting out any work (does
not apply to supplies, material, equipment, or
general support services).
C!l Program Office may restrict transfer of funds
among direct costs which exceed 10% of the
total approved budget and EPA amount is
greater than $250,000.
C!l Agreement includes construction and non-
construction must obtain prior approval before
transferring funds from construction to non-
construction or vice versa.
C!l Changes in third-party services for central
program activities (e.g., contractors performed
majority of work).
C!l Incur pre-award costs 90 calendar days prior to award.
C!l Extend the expiration date of the award one time for up to 12
months. One-time extension may not be initiated if:
Terms & conditions prohibit.
Additional funds are required.
Extension involves changes in the approved objectives or
scope of the project.
Extending merely for using up unobligated balances.
NOTE: EPA AWARD OFFICIAL MUST BE NOTIFIED IN WRITING WITH
REASONS & REVISED EXPIRATION DATES (AT LEAST 10 DAYS
BEFORE THE EXPIRATION DATE SPECIFIED IN THE AWARD)
§200.458 Pre-award Costs
- Pre-award costs must be included in application
- Applicant incurs pre-award costs at its own risk
- EPA will only allow pre-award costs without approval if there
are sufficient programmatic reasons for incurring the expenditure
prior to award
- Pre-award costs must conform with the appropriate costs
principles and procurement must comply with requirements of 2
CFR Part 200
§200.308 Revision of Budget and Program Plans
- Recipient must use the same format for budget information
that was used in the application unless awarding agency indicates
a letter of request suffices.
- PO must notify the recipient whether budget revisions have
been approved otherwise, inform recipient of the date when
recipient may expect the decision.
66
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POST AWARD CHANGES FOR STATES & LOCAL GOVERNMENTS
[For Continuing Environmental Program (CEP) Agreements Awarded Under 40 CFR Part 35, Subpart A **]
FORMAL AMENDMENT
REQUIRED
40 CFR §35.114(b)*
PRIOR WRITTEN APPROVAL
REQUIRED FROM EPA
40 CFR §35.114(a)*
PRIOR APPROVAL NOT
REQUIRED
40 CFR §35.114(c)
APPLICABLE TO:
- STATE AND
LOCAL
GOVERNMENT
** NOTE: This subpart
does not supersede
2 CFR §200, Subpart
E (Cost Principles)
which identifies certain
items of costs requiring
prior approval.
- Revisions which will result in
the need for additional funding
- Extend period of
performance or availability of
funds
NOTE: Should recipients beain
implementing a change before
the formal amendment has
been signed/approved by EPA,
they do so at their own risk.
EPA will notify recipients in
writing if requested changes
are disapproved.
- Sianificant chanaes to workplan
commitments and/or budget.
NOTE:
—~ "Significant" is not defined
under this subpart. Therefore,
recipients are encouraged to
consult with the EPA Project
Officer - to determine "significant"
and "insignificant" changes -
before chanaina the EPA-
approved workplan.
—~ Documentation of requests
and approvals for changes or
revisions, including associated
budgets, is required.
- Except for situations described
in §35.114(a)* and (b)*,
recipients do not need to obtain
approval for chanaes, unless
EPA determines that additional
approval requirements should be
imposed on a specific recipient,
on a case-by-case basis.
NOTE: EPA will notify specific
recipients in writing or by term(s)
and condition(s) contained within
the assistance agreements, if
additional EPA approval
requirements are imposed.
67
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POST AWARD CHANGES FOR TRIBES
(For Continuing Environmental Program (CEP) Agreements Awarded Under 40 CFR §35, Subpart B**)
APPLICABLE TO:
FORMAL AMENDMENT REQUIRED
PRIOR WRITTEN APPROVAL REQUIRED FROM EPA
PRIOR APPROVAL NOT REQUIRED
40 CFR § 35.514(b)*
40 CFR § 35.514(a)*
400 CFR § 35.514(c)
TRIBES
¦ Revisions which will result in
Prior written approval from the EPA Project Officer
Except for situations described in
the need for additional
include:
§35.514(a)* and (b)*, recipients do not need
INTERTRIBAL
funding
to obtain approval for changes, unless EPA
CONSORTIA OR
1) Sianificant post-award chanaes to workplan
determines that additional approval
CONSORTIUM
¦ Extend period of
commitments and/or budget.
requirements should be imposed on a
performance or
2) Increases in grant amounts
specific recipient, on a case-by-case basis.
* * This subpart
availability of funds
3) Project period extensions
does not
NOTE: EPA will notify specific
supersede 2 CFR
NOTE: Should recipients
NOTE:
recipients in writing or by term(s)
§ 200, Subpart E
begin implementing a change
~ "Significant" is not defined under this
and condition (s) contained within the
(Cost Principles)
before the formal amendment
subpart. Therefore, recipients are
assistance agreements, if additional
which identifies
has been signed/approved by
encouraged to consult with the EPA Project
EPA approval requirements are
certain items of
EPA, they do so at their own
Officer — to determine "significant" and
imposed.
costs requiring
risk. EPA will notify
"insignificant" changes — before changing
prior approval.
recipients in writing if
the EPA-approved workplan.
requested changes are
~ Documentation of requests and approvals
disapproved.
for changes or revisions, including associated
budgets, is required.
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From: Recipient Program Manager SAMPLE OF A
To: EPA Project Officer REBUDGETING
Cc: EPA Grants Specialist, Recipient's Finance Officer
Subject: Recipient's Name: Grant Number, Budget Modification #1
Attached: Re-budget Request, Revised 424A
Dear Project Officer,
REQUEST
We are requesting that $8,000 budgeted in Travel & Other be re- budgeted to the Equipment & Contractual expense categories because the
amount we had to spend for the recycling composters was more than we had originally estimated. Based on our conversation earlier this month,
we are requesting approval of this re-budget in order to support Tasks 3 and 4 of the workplan. Please see attached for our revised 424A.
Sincerely,
Recipient Project Manager
From: EPA Project Officer
To: Recipient
Cc: EPA Grants Specialist, Recipient's Finance Officer
Subject: REPLY: Recipient's Name: Grant Number, Budget Modification #1
Dear Recipient's Program Manager,
I approve your request to re-budget $8,000 in Travel & Other to the Equipment & Contractual category based on the justification you provided.
Sincerely,
EPA Project Officer
69
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SAMPLE - REBUDGET
BUDGET INFORMATION - Non-Construction Programs ombApproval N0.03M-0044
SECTION A - BUDGET SUMMARY
Grant Program
Function
or Activity
fa)
Catalog of Federal
Domestic Assistance
Number
(b)
Estimated Unobligated Funds
New or Revised Budget
Federal
(c)
Non-Federal
(d)
Federal
(e)
Non-Federal
(0
Total
(g)
1. PWSS
66.432
$
$
$465,000
$155,000
$620,000
2.
3.
4.
5. TOTALS
$465,000
$155,000
$620,000
SECTION B - BUDGET CATEGORIES
6. OBJECT CLASS CATEGORIES
Total
(5)
(1) Old Budget
(2) Revised Budget
(3)
(4)
a. Personnel
$310,993
310,993
$
$
b. Fringe Benefits
65,308
65,308
c. Travel
15,179
10,179
d. Equipment
52,000
57,000
e. Supplies
8,650
8,650
f. Contractual
60,000
63,000
g. Construction
0
0
h. Other
13,795
10,795
i. Total Direct Charges (sum of 6a - 6h)
525,925
525,925
j. Indirect Charges
94,075
94,075
k. TOTALS (sum of 6i and 6j)
620,000
620,000
7. Program Income
$
$
$
$
$
70
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Managing Unspent (Unexpended/Unobligated) Grant Funds
Regular and timely submissions of an annual (interim) Federal Financial Report (SF 425) and Progress Reports are integral
requirements of an EPA grant agreement. EPA Project Officers and Grants Specialists review these reports to confirm that the
amount of funds expended under the grant align to the technical and administrative requirements of the grant's terms and
conditions. In situations when a reconciliation is required between project tasks completed versus unexpended funds, a discussion
with the EPA Project Officer should be initiated. Determine whether the grant outputs and outcomes specified in the work plan are
being achieved. If a discrepancy exists between unspent funds within the grant's lifecycle, action steps are required.
Sample Grant - Under 40 CFR Part 35
Regulation
Year 1-Initial Award
$85,000
Year 2- Amendment #1
• Add: $90,000
• Total: $175,000
10/01/2019
START
09/30/2020
09/30/2021
END
1. All funds and expenses are tracked cumulatively until the grant end date (9/30/2021).
a.
b.
c.
If Year 1 activities are completed and funds unspent, the recipient should contact the EPA Project Officer
on how funds can be used for other activities approved in the workplan within the start and end dates
of the grant.
If Year 1 activities are NOT completed and funds unspent, the recipient should contact the EPA Project
Officer on how the activities should be completed and funds spent in the following year - but before
the grant ends in 9/30/2021.
If Year 2 activities are behind based on the project schedule, the recipient and EPA Project Officer
should discuss how best to complete the activities by the grant end date and/or revise the workplan
with realistic, concrete activities to complete by the grant end date.
2. By the end of the grant (9/30/2021), all workplan tasks should be completed. The FINAL Federal Financial Report
(SF 425) should be submitted to the EPA Research Triangle Park Finance Center (RTPFC at rtpfc-grantsffiepa.gov)
within 120 days from the grant end date (01/30/2022).
3. Once the EPA-RTPFC receives the FINAL Federal Financial Report (SF 425), any unobligated balances
(unspent funds) reported on the FINAL SF 425 will be de-obligated.
4. NOTE: At the end of the grant, workplan activities and the funds spent should match up. If certain workplan
activities have not been completed due to unforeseen circumstances, the recipient and the EPA Project Officer
must discuss the status of these workplan activities and whether the funds spent agree with work completed.
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Keeping Records of the Grant's Financial Transactions
Costs incurred under a grant must be supported by "source documentation," such as invoices, receipts, bills, online transaction
confirmations, and other items. In addition to recording financial transactions in the recipient's accounting system, records
must be maintained to support those transactions. The EPA, including the Office of Inspector General (OIG), periodically
examines assistance agreements to ensure that grant funds are being used efficiently and effectively. Such audits may involve
assessing the allowability of grant costs and compliance with grant requirements, terms and conditions. Setting up a
comprehensive and organized grant file will greatly facilitate responses to an audit, including any Administrative Advanced
Monitoring (AAM) reviews, by which the recipient's drawdowns are compared with back-up documentation to confirm that
funds were spent on allowable costs and that they were properly allocated to thegrant.
AREA OF COST
Supporting Source Documentation
Applies to all Federal and Non Federal (Cost Share) Costs
(dates of service or goods purchased should appear on all documentation)
Personnel / Payroll
(Includes Fringe Benefits)
• Time/Attendance Records - Time sheets
• Time/Attendance Amendments
• Worksheet showing fringe benefit
calculations (if not calculated by
accounting system)
• Proof of payment (copies of checks or bank statements)
T ravel
• Authorization (including purpose of trip)
• Travel voucher showing:
o Approval signatures, as required
o Starting point & destination
o Transportation method
o Number & names of persons on trip
• Receipts (airline, hotel, etc.)
• Proof of payment (copies of checks or bank statements)
Equipment/ Supplies
• Authorization to purchase item
• Hourly records of equipment use (if applicable)
• Invoice from vendor
• Receipt of item & approval of invoice
• Proof of payment (copies of checks or bank statements)
Contractor Services
• Signed contract
• Contractor's invoices (include date of service)
• Receipt & approval of invoices
• Proof of payment (copies of checks or bank statements)
Cost / Price Analysis
(2 CFR §200.323)
• Documents supporting cost or price analysis in connection with every procurement
action in excess of the Simplified Acquisition Threshold (currently set at $250,000)
including contract modifications.
Other (i.e., training/
tuition, phones, repairs,
subawards, etc)
• Travel vouchers, etc. (see "Travel" above)
• Receipts (airline, hotel, tuition, etc.)
• Copies of phone bills, other invoices
• Copies of awards
• Proof of all payments (copies of checks or bank statements)
Indirect Costs (Overhead)
• Indirect cost rate proposal submitted to Cognizant Federal Agency
• Indirect Cost Rate Agreement
72
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e
GRANT CLOSEOUT (CLOSURE)
What's a Grant Closeout?
Closeout refers to the process EPA uses to determine that a recipient has completed all the required technical work under
a grant and confirm that all applicable financial and administrative requirements have been met. Per federal grant
regulations (2 CFR § 200.344 Closeout), the recipient must submit, no later than 120 calendar days after the end date of
the period of performance, all financial, performance, and other reports as required by the terms and conditions of the
Federal award, unless EPA agrees to a time extension. The closeout process involves three separate offices: Research
Triangle Park Finance Center (RTPFC), the EPA Regional Program Office, and the EPA Regional Grants Branch. RTPFC
reviews the final FFR and reconciles it against the recipient's drawdowns. The Program Office certifies that the technical
work has been completed, work plan requirements met, and compliance with program terms and conditions. The Grants
Branch receives a copy of the final FFR from RTPFC, the Project Officer's closeout certification, and any outstanding
reports from the recipient for review and completion of the administrative grant closeout. The grant is closed when all
three EPA offices complete their portion.
List of Required Documents to be Submitted for Closeout:
S Final Federal Financial Report (FFR) - Standard Form 425 - due within 120 days after grant end date
S Final Progress Report (Final Technical & Performance Report) - due within 120 days after grant end date
S Personal Property Report and Disposition Instructions (if applicable)
S Final MBE/WBE (Minority/Women-Owned Business Enterprise Form 5200-52A) (if applicable)
S Any additional report or deliverables under the terms and conditions of the award - due within 120 days after
grant end date
CLOSING OUT THE EXPIRED GRANT:
THE PROCESSING OF THE FINAL FEDERAL FINANCIAL REPORT (FFR)
1. RTPFC may send a final FFR reminder within 30 calendar days after the grant expires.
a. If final FFR is not received within 120 days after the grant expires, RTPFC may send a "2nd Notice-Overdue FFR" email to the recipient (ASAP automatically locks the
account associated with the expired grant).
b. If final FFR is still not received by 30 days of date of 2nd Notice, RTPFC may contact the recipient by phone.
c. RTPFC will forward the issue to the EPA Grants Specialist, who will then follow up with the recipient if the final FFR remains unsubmitted.
2. RTPFC reviews the final FFR for accuracy and reconciles it against the recipient's drawdowns. If RTPFC finds a problem, the recipient will be contacted.
3. RTPFC forwards copy of final FFR to the EPA Grants Specialist and Project Officer.
4. EPA Project Officer certifies to the Grants Specialist that the technical work has been completed, work plan reguirements and any program conditions have been meet.
EPA Grants Specialist verifies that administrative conditions were met.
5. Grant is officially closed out with the EPA.
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Equipment Disposition Requirements for Non-Superfund Grants
£ f % V
tlTf
m -n |i BO
Under 2 CFR 200.33, Equipment is defined as tangible personal property that has a (1) useful life of more than 1 year and (2) a
unit acquisition cost of $5,000 or more. After a grant expires, grant recipients may continue using equipment on the project
originally funded through the grant and/or other federally funded projects, regardless of whether the program or project
continues to be supported by federal grants. However, EPA may provide alternate disposition instructions in a term and condition
stipulated in the official award document or at closeout. The table below lists the disposition requirements for states and
tribal/local government, institutions of higher education and other non-profit organizations.
RECIPIENT DISPOSITION OBLIGATION TO EPA
CATEGORY
STATES
Determined by State
Law and Procedures
None
2 CFR §200.313 (b)
INDIAN TRIBES,
LOCAL
GOVERNMENTS,
INSTITUTIONS OF
HIGHER
EDUCATION &
OTHER NON-
PROFIT
ORGANIZATIONS
1) Equipment with Fair
Market Value of Less
Than $5,000
2) Equipment with Fair
Market Value of More
than $5,000
None. Recipients may retain, sell
or otherwise dispose of the
equipment with no further
obligation to EPA.
2 CFR §200.313 (e)(1)
When no longer used for original
project or program or for other
activities currently or previously
supported by a Federal awarding
agency, the Recipient may retain
or sell the equipment, but EPA is
entitled to an amount that is
calculated by multiplying the
current market value or proceeds
from a sale by EPA's percentage
of participation in the cost of the
original purchase. Recipient
should contact the EPA Project
Officer to confirm proper
disposition of equipment
purchased with EPA funds.
2 CFR §200.313 (c-e)
74
Acquisition
cost of $5,000
and more per
unit, and a
useful life of
more than 1
year.
See full Definition of
Equipment in 2 CFR
200.33: A useful life of
more than 1 year, and
a unit acquisition cost
of $5,000 or more.
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Record Retention Requirements
(EPA Grants except Superfund Cooperative Agreements)
Recipients should set up at the beginning of the project a grant project file to maintain relevant financial and
programmatic information. Financial records, supporting documents, and all other records pertinent to a federal award
must be retained for at least 3 years from the date the final Federal Financial Report is submitted. Some grant programs
require longer retention periods. For example, the Superfund cooperative agreement's record retention is 10 years per
40 CFR §35.6705(b) & (d). Check 2 CFR §200.333 for full list of exceptions.
TYPE OF RECORD
LENGTH OF RETENTION
APPLICABLE
GRANT
REGULATIONS
GRANT RECIPIENT
RECORDS (all financial,
program, and other
records which support or
are pertinent to assistance
agreement or to grant
regulations)
Records must be retained for three (3) years from the date of
submission of the final expenditure report.
There are a few exceptions to the record retention period:
You may need to keep the records longer if any litigation,
claim, negotiation, audit or other action involving
the records started before the record retention period
expired.
The records must be retained until the action has been
completed and all issues that arise from it are resolved, or
until the end of the regular 3-year period, whichever is later.
You must keep records for real property and equipment
acquired with federal funds for three years after the final
disposition of the property.
2 CFR §200.333
RECORDS MAINTAINED BY
GRANT RECIPIENTS'
CONTRACTOR
Retention of all required records for three years after
recipients or subrecipients make final payments and all other
pending matters are closed.
ACCESS-T0-REC0RDS 2 CFR §200.336: The federal awarding agency, the Office of the Inspector General,
the Comptroller General of the United States and the pass-through entity, or any of their authorized
representatives, must have the right of access to any documents, papers, or other transcripts. The right
also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of
interview and discussion related to such documents.
The rights of access in this section are not limited to the required retention period, but last as long as the
records are retained. Federal awarding agencies and pass-through entities must not impose any other
access requirements upon non-Federal entities.
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Tips for Achieving Financial & Administrative Management Success
with an EPA Grant
This section provides key points and tips for achieving success in complying with all three phases of the EPA grant
funding cycle (Preaward, Postaward, and Closeout). Individuals involved in the preparation and submission, including
the financial and administrative management of an EPA grant, will find these tips particularly useful in performing self-
assessment checkmarks for complying with each stage of their EPA grants.
GENERAL: The Grant's Qualifying Funding Requirements
~ EPA Grants website: https://www.epa.gov/grants
~ EPA Grants Management Training for Applicants and Recipients
Go to https://www.epa.gov/grantsto obtain a broad spectrum of information and resources for applicants and recipients on EPA's
grant programs, latest grant opportunities, application process, including helpful training "EPA Grants Management Training for
Applicants and Recipients."
~ Check for specific grant requirements - federal agencies may have differing grant requirements.
~ Contract laws and regulations are different from grant laws and regulations; contracts are NOT grants.
~ Check the grant program being funded - program grant requirements are specific to the laws and regulations of that program and
to the specific type of money used.
~ Check-in with your (recipient) Finance Office and communicate with them on a regular basis.
APPLICATION & BUDGET: A Well Developed Application Package
n Check to ensure the organization's SAM registration is active and current; and, Grants.gov is set up properly with assigned levels
of review and approvals.
~ Check the grant application deadline date - to provide applicants enough time to make required changes.
~ Check if all application items have been submitted. Review the R9 Application Guide which includes an Application Checklist of
all forms (and the links to forms) required for a complete application. Incomplete applications may cause delays in receiving federal
funding.
~ Check if all numbers on application pages add up and are consistent with each other.
~ Check if the budget includes computers, printers, furniture, etc. -- these items need to be tracked per 2 CFR, Part 200.310
Property Standards.
~ Check that the application has been signed by the Authorized Organization Representative (AOR) via Grants.gov.
INDIRECT COSTS (OVERHEAD): Key Points to Remember
~ Check for the approved, current Indirect Cost Rate Agreement. In order to be reimbursed for indirect costs, the recipient must
have an approved, current indirect cost rate for the applicable period. Certain recipient types are eligible to maintain a Cost
Allocation Plan or Indirect Cost Rate Proposal.
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~ Check to ensure Indirect Cost Rate proposal are submitted timely to the cognizant agency, if applicable.
~ Check the calculation of your approved Indirect Cost Rate for the current indirect rate, the base used (i.e., personnel and fringe,
or total direct costs), and the time period of the agreement.
~ If the recipient wishes to charge/budget a lower indirect cost rate than the approved negotiated rate, the organization's Finance
Office must provide a statement allowing the use of the lower rate.
GRANT AWARD: What to Do Upon Receipt of the Award Document
~ Once the recipient contact receives the EPA Notice of Assistance Agreement, forward a copy to all appropriate staff (i.e., Project
Manager, Financial Officer, and any other personnel in your organization requiring information about the award).
~ Review the assistance agreement; terms and conditions; note the budget/project period start and end dates; and reporting due
dates.
~ Drawdown of funds is acceptance of the assistance agreement in the Federal requirements.
~ Finance staff, especially those responsible for draw down of grant funds, must always have the current assistance agreement
including all amendments thereto.
PAYMENTS: Reimbursements & Draw Down of Funds
~ Payment requested expenses must be within the assistance agreement's budget/project start and end dates.
~ Payment requested must be for tasks/work indicated in the approved workplan.
~ Invoices may be paid up to 90 calendar days after the grant end date for approved costs based on the workplan covered within
the assistance agreement's budget/project start and end dates.
~ Recipients have access to the payment system up to 90 calendar days after the budget/project end dates.
~ For information regarding payments and financial reports, please refer to the following website at
https://www.epa.gov/financial/grants.
~ If you have questions or need assistance, please contact EPA's Research Triangle Park Finance Center at rtpfc-grantsffiepa.gov or
(919) 541-1550.
REPORTS: Submitting Required Reports
~ Annual/interim Federal Financial Report SF 425 (Excel) (FFR) forms are submitted to Research Triangle Park Finance Center
(RTPFC); email: rtpfc-grantsffiepa.gov. (see Administrative Terms and Conditions).
~ Final Federal Financial Report SF 425 (Excel) (Final FFR) are due within 90 days (effective 11/12/2020:120 days) of the
budget/project period end dates to Research Triangle Park Finance Center (RTPFC); email: rtpfc-grants@epa.gov. (see Administrative
Terms and Conditions).
~ Once the Final FFR is received by RTPFC, they will reconcile the payment history to the Final FFR. RTPFC will provide an
Assistance Adjustment Notice to the recipient if payment is required or if funds need to be returned back to EPA.
~ Check the assistance agreement's Administrative terms and conditions if the Minority/Women's Business Enterprise Utilization
Report (MBE/WBE) EPA Form 5700-52A reports are required or not.
~ Check the assistance agreement's Programmatic terms and conditions for when Progress Reports are due (Quarterly, Semi-
Annually, or Annually).
~ Final Progress Reports are due to the EPA Project Officer within 90 calendar days of the budget/project period end dates.
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EPA Region 9 Commonly-Used Acronyms
The following is a listing of the most common acronyms in EPA grant-talk.
AAM Advance Administrative Monitoring
AAN Assistance Adjustment Notice
ACH Automated Clearinghouse (phased out by EPA)
AFC Audit Follow-Up Coordinator
AOR Authorized Organizational Representative
AIEO American Indian Environmental Office
ASAP Automated Standard Application for Payment
CAP Corrective Action Plan
CAP Cost Allocation Plan
CCR Central Contractor Registration
CEP Continuing Environmental Program
CFDA Catalog of Federal Domestic Assistance
("Assistance Listings" from GSA's beta.SAM.gov)
CFO Chief Financial Officer
CFR Code of Federal Regulations
COI Conflict of Interest
DBE Disadvantaged Business Enterprises
DDO Dispute Decision Official
DUNS Dun & Bradstreet Universal Numbering System
(GSAto discontinue its use by 12/ 2020)
EFT Electronic Funds Transfer
EIN Employer Identification Number
EPA Environmental Protection Agency
FAC Federal Audit Clearinghouse
FAR Federal Acquisition Regulation
FFATA Federal Funding Accountability and Transparency Act
FFR Federal Financial Report
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FOIA
Freedom of Information Act
FON
Funding Opportunity Number
FSRS
FFATA Subaward Reporting System
GAAP
Generally Accepted Accounting Principles
GAO
Government Accountability Office
GAP
General Assistance Program
GMO
Grants Management Officer
GPI
Grants Policy Issuance
GS
Grants Specialist
GSA
General Services Administration
IAE
Integrated Award Environment
ICR
Information Collection Request
ICR
Indirect Cost Rate
IDC
Indirect Cost
MBE/WBE
Minority Business Enterprise/Women Business Enterprise
OCFO
Office of the Chief Financial Officer
OCR
Office of Civil Rights
OGC
Office of General Counsel
OGD
Office of Grants and Debarment
OITA
Office of International and Tribal Affairs
OIG
Office of the Inspector General
OMB
Office of Management and Budget
ORC
Office of Regional Counsel
PI
Principal Investigator
P.L.
Public Law
PM
Project Manager
PO
Project Officer
PRA
Paperwork Reduction Act
OA
Quality Assurance
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RA Regional Administrator
RAIN Recipient/Applicant Information Notice
RFA Request for Applications
RFIP Request for Initial Proposal
RTPFC Research Triangle Park Finance Center
RTOC Regional Tribal Operations Committee
SF Standard Form
SAM System for Award Management
SPOC State Single Point of Contact
SRO Senior Resource Official
TIN Taxpayer Identification Number
T&C Terms & Conditions
UGG Uniform Grants Guidance (2 CFR, Part 200)
UEI Unique Entity Identifier
(GSA to fully implement use by 12/ 2020)
U.S.C. United States Code
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How to Reach Us: The EPA Region 9 Grants Branch
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
EPA Region 9 Grants Branch, MSD-6
Grants Management Officer
Carolyn Truong tmong.carolyn@epa.gov (415) 947-4268
Grants Management Specialists
Veronica Adams, adams.veronica@epa.gov
Fareed AN, ali.fareed@epa.gov
Elizabeth Armour, armour.elizabeth@epa.gov
Danielle Carr, carr.danielle@epa.gov
Susan Chiu, chiu.susan@epa.gov
Alba Espitia, espitia.alba@epa.gov
Darlene Fernandez fernandez.darlene@epa.gov
Angela Mendiola mendiola.angela@epa.gov
Abimbola Odusoga odusoga.abimbola@epa.gov
Maria L. Roverso, roverso.maria@epa. gov
Kimberli Smith smith.kimberli@epa.gov
Nelly Sun sun.nellv@epa.gov
Martha Villarreal villarreal.martha@epa.gov
(415) 972-3677
(415) 972-3665
(415) 947-4264
(415) 972-3871
(415) 972-3674
(415) 972-3667
(415) 972-3664
(415) 972-3284
(415) 972-3437
(415) 972-3573
(415) 972-3778
(415) 947-4237
(415) 972-3666
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