BEST PRACTICES GUIDE
for Performance Partnership Grants
with States
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Table of Contents
Purpose 3
What are Performance Partnership Grants? 4
Section I: Introduction to Performance Partnership Grants (PPGs) 4
Which statutes and regulations apply to PPGs for States? 4
What are the advantages of PPGs? 4
Are there any challenges with PPGs? 6
How can new or existing grant programs be deemed eligible for inclusion in a PPG? 6
What state agencies are eligible to receive PPGs? 6
Can a state receive more than one PPG? 7
Which grant programs are eligible for inclusion in PPGs? 7
Section II: Applying for and Negotiating a PPG 9
What activities are eligible for funding under PPGs? 9
What is the period of performance for a PPG? 9
What needs to be included in a PPG work plan? 9
What is the relationship between PPGs and PPAs? 10
How do the National Program Guidances (NPGs) influence PPG work plans? 11
What is the general planning cycle for development of a PPG work plan? 11
How does a state apply for a PPG? 12
What needs to be included in a PPG application? 12
Can a state include competitive funds in a PPG? 12
Do state PPGs have cost share requirements? 13
Can voluntary cost share be included in a state PPG? 14
Section III: Managing a PPG 16
How is PPG performance evaluated? 16
Can changes be made to an approved PPG work plan? 17
Can the period of performance for a PPG be extended? 18
What is the EPA Quality Program? 18
What is a Quality Management Plan (QMP)? 19
What is a Quality Assurance Project Plan (QAPP)? 19
What is the difference between a QMP and a QAPP? 19
How does a PPG recipient draw down funds? 19
If funds remain after all work is complete, what can a recipient use those funds on? 20
Section IV: Closeout 21
What does closeout mean? 21
What is the process for closeout of a PPG? 21
Program-Specific Requirements 22
Appendix A: Glossary of Terms 23
Appendix B: Frequently Used Acronyms 25
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Purpose
This Best Practices Guide for State Performance Partnership Grants serves as a reference tool for EPA
and state officials, at both the management and staff level, to better understand and apply the
numerous features and benefits of Performance Partnership Grants (PPGs).
States continually seek to expand the use of PPGs to best leverage resources and optimize the
efficiencies and flexible approaches toward meeting joint environmental goals and priorities. EPA
and state counterparts regularly collaborate in sharing best practices and approaches in managing
PPGs, much of which is captured within this guide.
Using a question-answer format, this guide:
• Explains how PPGs can help achieve agreed-upon environmental goals and objectives.
• Highlights key regulations, policies, and procedures for developing and managing PPGs.
• Provides examples showing how PPGs have been used to achieve administrative efficiencies
and direct resources to support state priority environmental programs and results.
• Provides information and resources for state and federal personnel involved in negotiating,
managing, and maintaining PPGs.
• Offers a glossary of terms, and active links to training and reference materials to allow the
user to further explore the context and related information influencing PPG implementation.
This document is meant to provide supplemental information regarding PPGs that may not be
included in the Office of Congressional and Intergovernmental Relations' (OCIR) National Program
Guidance. The best practices guide will be continually updated as topics are raised by PPG recipients
and their EPA regional counterparts. To raise a topic or question that you believe should be
addressed in this guide, please email regionaloperations(5)epa.gov with "State PPG Best Practices
Guide" in the subject line.
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Section I: Introduction to Performance
Partnership Grants (PPGs)
What are Performance Partnership
Grants?
A Performance Partnership Grant (PPG) is a
single grant combining funds from two or
more eligible environmental program grants.
A PPG requires only a single application, work
plan, and budget, regardless of the number of
eligible programs included in the PPG.
Recipients are encouraged to use PPGs to
fully capitalize on their ability to leverage EPA
financial assistance and optimize flexibilities
through joint priority setting while minimizing
reporting requirements and financial
constraints. Once funds are awarded in a PPG,
the recipient can direct the funds as needed
to achieve work plan commitments and does
not need to account for funds in accordance
with their original program sources. Unlike
consolidated grants. PPGs have their own
statutory authority distinct from individual
program statutes, which provides unique
flexibilities to recipients enjoyed by no other
grant program at EPA.
Which statutes and regulations
apply to PPGs for States?
For many years, states wanted greater
flexibility in how they use and manage the
grant funds they receive from EPA. In 1995,
EPA asked Congress for new authority to
provide this flexibility. In response, Congress
authorized EPA to award assistance
agreements that combine funds from two or
more of the eligible environmental program
grants without the restrictions of consolidated
grants, and those agreements were titled
Performance Partnership Grants or PPGs.
The statutory authority to award PPGs was
provided to EPA in the Omnibus Consolidated
Rescissions and Appropriations Act of 1996
(Public Law 104-134) and in EPA's 1998
Appropriations Act (Public Law 105-65). EPA
established regulations governing the award
and administration of PPGs to states in 40 CFR
Part 35. Subpart A ("Environmental Program
Grants").
In addition, all EPA grants, including PPGs,
must also comply with the EPA general
assistance regulations in 2 CFR Parts 200 and
1500. known collectively as the Uniform
Administrative Requirements for Grants and
Cooperative Agreements, or Uniform Grant
Guidance (UGG), and 40 CFR Part 33.
Participation by Disadvantaged Business
Enterprises in United States Environmental
Protection Agency Programs.
What are the advantages of PPGs?
A Performance Partnership Grant allows
states to realize administrative savings and
provides states with programmatic flexibility
to direct grant resources where they are most
needed to address public health and
environmental priorities. PPGs streamline
administrative requirements, give state
agencies greater flexibility to direct resources
to their most pressing environmental
problems, and make it easier to fund efforts
that cut across program boundaries. Under
standalone environmental program grants,
state agencies receive funds to administer
and implement air, water, waste, pesticides,
and toxics programs. Each standalone grant
can only be used for the specific purposes set
out in the authority for that grant.
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PPGs enable states and interstate agencies to
combine funds from more than one
environmental program into a single grant
with one budget, one financial status report,
and one negotiated work plan that groups
work plan commitments by component. When
environmental program grant funds are
combined into a PPG, the program funds are
no longer required to be tracked by the
original program source. This reduces the
administrative burden of managing grants by
streamlining paperwork and accounting
procedures.
MAXIMIZE AVAILABLE RESOURCES
States may elect to leverage a PPG to fund
innovative projects or special initiatives. For
example, a state may want to use a PPG to
fund multimedia inspections to assess
compliance with air, water, and hazardous
waste management requirements. If the PPG
combines funds from the Clean Air Act (CAA)
§105, Clean Water Act (CWA) §106 and Solid
Waste Disposal Act (SWDA) §3011 (a)
programs, these multimedia inspections could
be funded through the PPG if included in the
approved PPG work plan. Conversely, the EPA
would not be able to approve multimedia
inspections that include evaluation of
compliance with underground storage tank
(UST) requirements or rules under the Toxic
Substance Control Act (TSCA) unless funds
from those grant programs were also
included in the PPG.
Distributing funds included in a PPG to
projects or activities that cut across program
boundaries can be a significant benefit. A
state may also use the PPG work plan
negotiation process to discuss opportunities
for work sharing.
PPGs are often developed in a process that
involves not only EPA and state program
managers but also more senior leaders who
bring a broader perspective about priorities to
the table. This can lead to PPG work plans that
better reflect the priorities of the state.
Another advantage of a coordinated work
plan process is that program managers are
made aware of the work of their counterparts.
Thus, they may be able to leverage resources
collaborating on efforts of mutual interest.
While EPA regions are responsible for
negotiating with states on requests for flexibility
in PPGs, if a state's proposal deviates
significantly from the National Program
Guidance, the Regional Administrator must
consult with the appropriate National Program
Office before approving the state's proposed
work plan. States are required, by 40 CFR
§35.137. to explain the reasons and expected
benefits of any requested programmatic
flexibilities in a proposed work plan.
Reduce administrative costs through
streamlined paperwork and accounting
procedures, e.g., single performance/
progress reports, Federal Financial Reports
(Standard Form 425).
Fund efforts that involve multiple
programs and activities that are eligible
under the environmental programs
listed in 40 CFR §35.101.
Focus EPA grant funds on priority
environmental program needs.
Reduce cost share requirements.
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Are there any challenges with
PPGs?
While a PPG can afford a state entity with
additional financial and administrative
flexibility during the grant's period of
performance, PPGs require increased
collaboration and coordination upfront to
successfully negotiate a work plan and
throughout the grant to report and track
progress. This guide will delve deeper into
these challenges and present best practices to
help alleviate them.
How can new or existing grant
programs be deemed eligible for
inclusion in a PPG?
For grant programs to be deemed eligible for
inclusion in a PPG, they must be funded
through the same specific appropriation as
the funds for PPGs: Categorical State and
Tribal Assistance Grants (STAG). Only funds
included in the categorical line item within the
STAG appropriation account are available for
inclusion in PPGs because the statutory
authority to award a PPG (Public Laws 104-
134 and 105-65) is limited to those funds.
Additional grant programs are thus made
eligible for inclusion in PPGs if they are
funded in the same line item for the
categorical environmental program grants.
If grant programs are funded in a separate
line item, they can be made eligible if
Congress makes clear through statutory
language that the program should be eligible
for inclusion in PPGs.
As provided in 40 CFR §35.133(b). the EPA
Administrator may, in guidance or regulation,
describe subsequent additions, deletions, or
changes to the list of state environmental
programs eligible for inclusion in PPGs.
EPA policy presumes newly eligible grant
programs will be approved for inclusion in a
PPG unless there is specific legislative
language stating the program may not be
included in a PPG. The Office of Congressional
and Intergovernmental Relations (OCIR) will
coordinate with the appropriate EPA program
offices to develop a decision package for the
Administrator's signature approving new
programs for PPG eligibility. If an EPA
program office believes a new STAG program
should be excluded from PPGs, the office
must notify OCIR. OCIR will convene meetings
with interested offices and raise the issue, as
necessary. The Administrator makes the final
decision as to whether or not a grant program
is approved for inclusion in PPGs.
What state agencies are eligible to
receive PPGs?
PPGs may be awarded to all states and
interstate agencies that are eligible to receive
funds pursuant to more than one eligible
categorical environmental program grant
authority [e.g., Clean Air Act (CAA) Section 105
and Clean Water Act (CWA) Section 106]. For a
state agency to be eligible, it must be
designated the state agency authorized to
receive grants under the environmental
programs to be combined in the PPG (see 40
CFR §35.134).
A state agency may be awarded funds within a
PPG for another state agency to perform
work. For example, a state environmental
agency may be awarded a PPG that includes
funding for a drinking water program (i.e.,
Public Water System Supervision—SDWA Sec.
1443(a)) even though the authority to
implement the drinking water program
resides with the state public health agency.
This is allowable if there is an agreement
between the environmental and public health
agencies about how the funds will be shared
between the agencies to carry out the
drinking water program.
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Congress authorized EPA to award PPGs to
interstate agencies, but only as provided in
authorizing statutes. Recipients must be
interstate agencies as defined by either the
CWA, the CAA, or both, depending on which
funds are included in the PPG. Specifically,
interstate agencies are eligible for PPGs that
include funds from the following programs:
Air Pollution Control (CAA Sec. 105); Water
Pollution Control (CWA Sec. 106); and
Wetlands Development Grants (CWA Sec.
104(b)(3)).
Can a state receive more than one
PPG?
Yes. Some situations where a state may opt to
have multiple PPGs include:
~ A state agency has multiple PPGs in
order to effectively align grant work
based on state programs/departments
(e.g., media-specific PPGs like a "water
PPG" and an "air PPG")
~ Timing of multi-year grant project would
cause an existing PPG to go beyond the
5-year limit, so a second PPG may be
awarded with new funds that overlaps
an existing PPG for a year or more.
States can have more than one active PPG,
but careful considerations must be made,
such as:
~ Expenditures must be carefully tracked
and documented to ensure costs are
charged to the appropriate grant.
~ The recipient must ensure records
support the distribution of the
employee's salary or wages among
specific activities or cost objectives, as
required by 2 CFR §200.430.
Which grant programs are eligible
for inclusion in PPGs?
There are currently 19 environmental
program grants eligible for inclusion in a PPG,
listed in Table 1 with the corresponding
assistance listing number. Assistance listings
are detailed public descriptions of federal
programs that provide grants, loans,
scholarships, insurance, and other types of
assistance awards. The assistance listing
number for PPGs is 66.605. For more
information on assistance listings, please
refer to https://sam.gov/content/assistance-
listings.
Since the inception of the National
Environmental Performance Partnership
System (NEPPS), there have been other EPA
grant programs eligible for inclusion in a PPG.
However, these programs were either
discontinued or are inactive and excluded
from the table below. Examples include
Multimedia Sector Program Grants and Water
Quality Cooperative Agreements (CWA
§104(b)(3)).
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Table 1. Eligible Environmental Programs for Inclusion in PPGs
EPA Office
Assistance Listing
Number
Environmental Program Grant
Office of the Administrator
66.204
Multipurpose Grants to States and Tribes
Office of Air and Radiation
66.001
Air Pollution Control Program Support
66.032
State Indoor Radon Grants
Office of Chemical Safety
and Pollution Prevention
66.707
TSCA Title IV State Lead Grants Certification of Lead-Based Paint Professionals
66.708
Pollution Prevention Grant Program
Office of Enforcement and
Compliance Assurance
66.700
Consolidated Pesticide Enforcement Cooperative Agreements1
66.701
Toxic Substances Compliance Monitoring Cooperative Agreements
Office of International and
Tribal Affairs
66.926
Indian Environmental General Assistance Program (GAP)
Office of Land and
Emergency Management
66.801
Hazardous Waste Management State Program Support
66.804
Underground Storage Tank Prevention. Detection, and Compliance Program
66.812
Hazardous Waste Management Grant Program for Tribes
66.817
State and Tribal Response Program Grants
Office of Mission Support
66.608
Environmental Information Exchange Network Grant Program and Related
Assistance
Office of Water
66.419
Water Pollution Control State. Interstate, and Tribal Program Support
66.432
State Public Water Svstem Supervision
66.433
State Underground Water Source Protection
66.460
Nonpoint Source Implementation Grants
66.461
Wetland Program Development Grants
66.472
Beach Monitoring and Notification Program Implementation Grants
1 Pesticide cooperative enforcement (section 23(a)(1) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)), pesticide applicator
certification and training (section 23(a)(2) of FIFRA), and pesticide program implementation (section 23(a)(1) of FIFRA) fall under this assistance
listing.
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Section II: Applying for and Negotiating a PPG ((Eg
What activities are eligible for
funding under PPGs?
The ability to fund a broad range of activities
is one of the most flexible features of PPGs.
PPG funds should address activities consistent
with the negotiated work plan and grantees
are required to implement program
requirements, but PPGs provide flexibility to
address priority environmental activities.
Flexibilities provide opportunities to utilize
PPG funds to address priorities and activities
under at least one of the categorical
environmental programs within the PPG, even
if a small portion of the available program
grant funds are included in a PPG. This is
commonly referred to as the "dollar in rule"
because if even one dollar is included in the
PPG from a given program, then PPG funds
exceeding that amount can be used for that
program as long as all the work plan
requirements are met.
What is the period of performance
for a PPG?
The period of performance for a PPG is
flexible and can be negotiated between EPA
and the recipient for up to a maximum of five
years. To maximize flexibilities and ensure
program continuity, it is a best practice to
apply for multi-year PPGs. Recipients are
encouraged to align their multi-year PPG work
plans with EPA's 2-vear National Program
Guidances (NPGs) to streamline the work plan
negotiation process and reduce
administrative burden.
What needs to be included in a PPG
work plan?
A PPG work plan should be the product of
joint planning, priority setting, and mutual
agreement between the state and EPA. The
PPG grant work plan is the result of
negotiations between EPA and state program
managers and staff.
Successful PPG work plan negotiations rely on
a predictable process that fosters prompt
resolution of issues, including elevation of
issues to senior management levels if
necessary. In successful work plan
negotiations, EPA and the state will reach a
mutual understanding and agreement about
what will be accomplished under the
agreement.
An approvable work plan, as outlined at 40
CFR §35.107. must specify:
~ The work plan components to be
funded under the grant;
~ The estimated work years and the
estimated funding amounts for each
work plan component;
~ The work plan commitments for each
work plan component and a time frame
for their accomplishment;
~ A performance evaluation process and
reporting schedule in accordance with
40 CFR §35.115: and
~ The roles and responsibilities of the
recipient and EPA in carrying out the
work plan commitments.
The work plan must also be consistent with
applicable federal statutes; regulations;
circulars; executive orders; and EPA
delegations, approvals, or authorizations.
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COMPONENTS AND COMMITMENTS
A work plan component is a negotiated set or
group of work plan commitments established
in the grant agreement. A PPG work plan
typically has more than one work plan
component. All states are provided flexibility
through the work plan negotiation process
and can organize work plan components in
any way that works best for them. For
example, components can be media specific,
or they can be cross-media, grouping together
similar activities that fall within multiple
media.
Work plan commitments are the outputs and
outcomes associated with each work plan
component. Outputs may be quantitative or
qualitative but must be measurable during an
assistance agreement funding period, while
outcomes must be quantitative and may not
necessarily be achievable within an assistance
agreement funding period. Outcomes may be
environmental, behavioral, health-related, or
programmatic in nature.
It is EPA policy to link proposed assistance
agreements to the Agency's Strategic Plan and
ensure that outputs and outcomes are
appropriately addressed in work plans and
performance reports.
While developing their work plan, states have
the option to use a state PPG work plan
template. This simplified document offers a
user-friendly approach to capturing the
essential elements for a grant work plan. This
template may also serve as a tool for tracking
and reporting environmental results. States
interested in learning more about the
template and integrating it into the PPG
process should contact their regional NEPPS
Coordinator and Project Officer (PO).
What is the relationship between
PPGs and PPAs?
A Performance Partnership Agreement (PPA)
may be defined as a high-level document
signed by state and Regional Senior
Leadership to identify joint environmental
priorities to be accomplished. While the scope
and content may vary, PPAs typically address
joint goals and objectives through work plan
commitments. PPAs also include the roles and
responsibilities of each partner and how they
will assess progress. PPAs include details of
program implementation needs, as well as the
planned approach to achieve the greatest
environmental results.
PPAs are based on an assessment of
environmental conditions and program
implementation needs as well as an analysis
of the approaches and tools that are most
likely to bring about the greatest
environmental results. Many states now use
the process of negotiating a PPA with its EPA
region as a mechanism for reaching mutual
agreement on joint priorities and grant work
plans.
A fundamental concept underlying PPAs is the
recognition that all states have unique
capacities, interests, and environmental
priorities. Each EPA-state partnership
negotiation accommodates for these
differences and considerations. Individual
PPAs can range from a general statement
about how the state and EPA will work
together as partners (perhaps identifying joint
priorities that will be addressed) to more
comprehensive, multi-program documents
that detail each party's roles and
responsibilities.
While the scope and content may vary, PPAs
typically set out goals and objectives, priorities
and plans, the roles and responsibilities of
each partner, and the measures they will use
to assess progress. The best PPAs are based
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on a state-specific assessment of
environmental conditions and program
implementation needs as well as analyses of
what approaches and tools are most likely to
bring about the greatest environmental
results.
A PPA, or a portion of a PPA, can serve as the
grant work plan for a PPG. The most strategic,
flexible, and outcome-oriented option for
states may be a comprehensive PPA that
serves as a PPG work plan. The PPA (or
portion thereof that serves as a grant work
plan) must meet the same work plan
requirements as for any state program grant.
The portion(s) of a PPA that serve as a work
plan must be clearly identified and
distinguished from the rest of the PPA. The
regulation at 40 CFR § 35.107(c) provides, in
summary, that:
An applicant may use a PPA or a portion of a
PPA as the work plan for an environmental
program grant if the portions of the PPA that
serve as all or part of the grant work plan:
~ Are clearly identified and distinguished
from other portions of the PPA
~ Meet the requirements in §35.107(b).
Though a PPG does not require an
accompanying PPA, the PPA provides the
strategic and collaborative underpinning for
PPGs.
How do the National Program
Guidances (NPGs) influence PPG
work plans?
EPA program offices issue NPGs to serve as
the two-year framework for EPA regions and
grant recipients to meet Agency national
priorities, strategies, and goals.
EPA regions and states should factor in the
priorities in the NPGs when they negotiate
grant work plans. To allow flexibility when
addressing regional and state needs, the
states are encouraged to develop work plans
that reflect jointly identified priorities as well
as state-specific environmental and
programmatic needs.
EPA typically issues the NPGs every two years,
typically in April. EPA encourages grant
negotiations to continue in the event a
program office is late in issuing its NPG, or
when a state fiscal year begins earlier than a
federal fiscal year. As outlined in 40 CFR
§35.107(aH3V states should use the NPG that
is in place at the time the state prepares its
grant application.
CONSIDERATION OF STATE PRIORITIES'
The PPG regulations require that state
priorities be considered, along with national
program and, if applicable, regional
supplemental guidance, in developing grant
work plans (see 40 CFR §35.107(aMm This
allows for state flexibilities to be applied to
propose grant work plans that differ from the
goals, objectives, and measures in the NPM
guidance.
If the state proposes a work plan that is
significantly different from the National
Program Guidance, the Regional
Administrator must consult and approve this
with the affected National Program Manager
before agreeing to the work plan. For PPGs
where the proposed differences affect more
than one program, the Regional Administrator
must consult with each affected National
Program Manager, along with OCIR.
What is the general planning cycle
for development of a PPG work
plan?
The schedule for developing PPG work plans
will vary by state depending on state fiscal
year and grant project cycle. As a best
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practice, applicants are encouraged to apply
for multi-year PPGs. States are encouraged to
align multi-year work plans with the issuance
of EPA's Strategic Plan and the two-year NPGs.
The states then develop preliminary priorities
and assess resource needs, based on the
results from the previous year's grant, EPA's
NPGs, and state priorities. Work plan
commitments are then proposed, discussed,
and documented in a draft work plan.
The state submits its work plan with its
complete PPG grant application to EPA at least
60 days before the beginning of the proposed
funding period (40 CFR §35.105) via
www.grants.gov. The EPA PO and Grants
Specialist (GS) then process the grant
application and ensure the grant is awarded in
a timelyfashion when the appropriated
program funds are available. For more
information, please see EPA's grants policy
issuance, GPI-12-06. regarding the timely
obligation, award, and expenditure of EPA
grant funds.
How does a state apply for a PPG?
All applications for new EPA assistance
agreement awards must be submitted using
www.grants.gov. Applicants that have limited
or no internet capacity should refer to the PDF
on the Exceptions to the Grants.gov
Requirement page describing the process to
request an exception.
PPG applications are to be submitted through
grants.gov at least 60 days before the
beginning of the proposed funding period. As
a best practice, applicants should consult their
regional NEPPS Coordinator or EPA Project
Officer (PO) to discuss submitting an
application and determine if more time is
needed for review. The steps to apply are as
follows:
1. Go to www.grants.gov.
2. Under the "Applicants" tab, click "How to
Apply for Grants."
3. Near the bottom-right of the page, click
the red button, "Search for Opportunity
Package."
4. In the field "Funding Opportunity
Number," type EPA-CEP-01 (leave the
"Opportunity Package ID" field blank)
and click "Search."
5. CFDA 66.605 can be found at the
bottom of the list; users can click
"Preview" to download the required
forms or "Apply" to begin the application
process.
Applicants with questions about submission
requirements, including required forms and
other materials, should contact their PO,
regional Grants Management Official (GMO),
or regional NEPPS Coordinator.
What needs to be included in a PPG
application?
An application for a PPG must contain:
1. A list of the environmental programs
and the amount of funds from each
program to be combined in the PPG;
2. A consolidated budget (SF 424, 424A
and a budget narrative) that includes
funding for all years in the grant period;
3. A consolidated work plan (including a
project narrative) that addresses each
program being combined in the grant
and meets the requirements of 40 CFR
§35.107:
4. EPA Form 4700-4: and
5. EPA Key Contacts Form.
Can a state include competitive
funds in a PPG?
Yes, a state may include competitively
awarded funds from PPG-eligible programs in
a PPG. Among the PPG-eligible grant
programs, there are currently three grant
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programs that award funds competitively to
states. Those programs are:
~ Pollution Prevention State Grants (PPA Sec.
6605)
~ State Wetlands Development Grants (CWA
Sec. 104(b)(3))
~ National Environmental Information
Exchange Network
As indicated in the Federal Register, a state
must first be selected in the competitive
process to include competitive grants in a
PPG. To maintain the integrity of the
competitive process and ensure that the work
that was the basis for EPA's selection of the
proposal is performed, the State must include
the work plan commitments proposed in the
competitive grant application in the PPG work
plan. As with other program funds included in
a PPG, the State does not need to account for
these funds in accordance with the funds'
original environmental program source.
EPA GRANT COMPETITION POLICY
Award of competitive grants must adhere to
the requirements of EPA Order: 5700.5A1.
"Policy for Competition of Assistance
Agreements." This policy ensures that grant
competitions are conducted according to
accepted government-wide principles. The
Agencys policy assures fair competition while
giving programs the flexibility to customize a
competition to maximize program results.
Each of the PPG-eligible competitive grant
programs issues unique guidance that
includes the criteria for award.
ADDING A COMPETITIVE GRANT TO PPGS <
If a recipient opts to include competitive funds
in a PPG, the budget and work plan
commitments from the competitively selected
application will be incorporated into the
budget and work plan of the PPG. This can be
done with an initial PPG award or through a
supplemental amendment to an existing PPG.
If the time required to complete work plan
commitments from the competitive program
is longer than the funding period for the
existing PPG, states must make provisions to
carry the activities (and funds, if appropriate)
to subsequent PPG funding period to
complete them. In some cases, extending the
period of performance for the PPG may be a
suitable option to ensure all the work plan
commitments are completed. In other cases,
opening a new PPG for the competitive
program to ensure ample time to complete
work plan commitments may be a better
option. This option would require the
applicant to identify an additional eligible
program to be combined in the competitive
program into the PPG.
As a best practice, the recipient should
consult with their Project Officer to determine
which option may work best.
Do state PPGs have cost share
requirements?
Many environmental program grants require
states to provide non-federal funds to support
the environmental program activities. This
state contribution is called a cost share and
there are two types of cost sharing provisions:
match and maintenance of effort (MOE).
With a PPG, the required amount of the state
cost share is the sum of the minimum non-
federal cost share required under each of the
programs combined in the PPG. The non-
federal share of a PPG may be expended on
work plan commitments without regard to the
original source of the cost share requirement.
The general rules for cost share are found at 2
CFR §200.306 and further described
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specifically for PPGs in 40 CFR §35.136 for the
individual environmental programs.
A match requirement is the portion of project
costs not paid for by federal funds or contributions
that generally requires the state to contribute a set
percentage of total project costs for the program.
A maintenance of effort requirement is a cost
share requirement that requires a state to
provide a sustained minimum level of investment
that is based on prior year expenditures,
regardless of the amount of the federal grant.
When the cost share becomes a part of the
PPG, it must be detailed in the budget and
must follow the federal grant regulations and
the specific terms and conditions of the grant.
Grant recipients may use non-federal
resources from any of the eligible categorical
environmental programs included in a PPG to
meet the cost share requirement. Once
included in the PPG, the non-federal funds
may be used to complete any of the approved
PPG work plan commitments.
The PPG approach to cost share is valuable to
states because states may have the necessary
resources to meet the required cost share in
one program, but not enough in another
program included in the PPG. In such cases, a
state can use excess cost share from one
program to cover the cost share requirement
for another program.
The cost share must be broken out in the
budget by cost category (e.g., personnel,
fringe, equipment, etc.) for each work plan
component, but does not need to be broken
out by program. For example, if a PPG
includes three programs, and only two
programs contain cost share, the PPG budget
would show the sum of cost share for those
two programs in personnel, the sum of cost
share for those two programs in fringe, and
so on. The recipient is not required to break
out the cost share by how much program X
and program Y are contributing to personnel,
fringe, and so on.
At the end of the grant period, the recipient is
required to submit a final Federal Financial
Report (FFR). The recipient is required to
document in the FFR that the required
composite cost share has been met. When a
recipient receives resources in a PPG, the
recipient is not required to show whether
each environmental program cost share
requirement has been met. The recipient
need only show that the total, composite
minimum cost share for the PPG was met.
See Table 2 below for PPG-eligible programs
with required state cost-share requirements.
Can voluntary cost share be
included in a state PPG?
Yes. As defined in 2 CFR §200.1. voluntary
committed cost sharing (referred to within
this document simply as "voluntary cost
share") means cost sharing specifically
pledged on a voluntary basis in the proposal's
budget or the federal award on the part of the
non-federal entity and that becomes a binding
requirement of federal award.
Because cost share initially included on a
voluntary basis becomes legally binding after
the PPG is awarded, applicants are
discouraged from including voluntary cost
share in their proposed PPG work plans and
budget. Instead, as a best practice, any state
funding put towards eligible PPG activities
beyond the required cost share should be
reported on in the recipients FFRs. This
amount can be reported on in line "j.
Recipient share of expenditures". This
additional funding is considered overmatch
and can be used to replace any costs that may
be disallowed over the course of the PPG
project period to minimize any potential
repayments.
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Table 2. PPG-EIigible Programs with State Match Requirements
PPG-Eligible Programs with Match
Requirements1
Required State Match
Pesticide Applicator Certification and Training - FIFRA
Sec. 23(a)(2)
50% of Total Project Costs (TPC)
Pollution Prevention Grant Program - (PPA Sec.
6605) (competitive)
50% of TPC
Air Pollution Control - CAA Sec. 105
Whichever is greater: 40% of TPC or MOE
Nonpoint Source Management - CWA Sec. 319
(>competitive)
Whichever is greater: 40% of TPC or MOE (average of
FY 1985 and 1986 expenditures)
State Indoor Radon Grants - TSCA Sec. 306
40% of TPC (for recipients with two or more years in
the program)
Hazardous Waste Management - SWDA Sec. 3011 (a))
25%ofTPC
Public Water System Supervision - SDWA Sec.
1443(a)
25%ofTPC
State Underground Water Source Protection
(Underground Injection Control) - SDWA Sec 1443(b)
25%ofTPC
Toxic Substances Compliance Monitoring - TSCA Sec.
28
25%ofTPC
Underground Storage Tanks - SWDA Sec. 2007(f)(2))
25%ofTPC
Wetlands Program Development - CWA Sec.
104(b)(3) (competitive)
25%ofTPC
Water Pollution Control - CWA Sec. 106
MOE equal to expenditures in FY endingjune 30,
1971
1 Source: CFDA 66.605, Performance Partnership Grants
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Section III: Managing a PPG
How is PPG performance
evaluated?
PPGs are subject to the reporting, joint
evaluation, and accountability requirements
of 40 CFR Part 35. States are held accountable
for achieving the commitments set out in
approved PPG work plans. States with PPGs
continue to report information into national
data systems and submit any other reports
required by regulation as outlined in the
terms and conditions of the award.
As discussed in EPA Order 5700.7.
Environmental Results Under EPA Assistance
Agreements, program offices must review
performance reports submitted by recipients
under 2 CFR §200.329 to determine whether
the recipient achieved the environmental
and/or public health outputs and outcomes
contained in the assistance agreement work
plan. This includes ensuring that performance
reports provide a satisfactory explanation if
outcomes or outputs were not achieved. The
review is to be documented in the official
project file.
REPORTING
PPGs can be comprised of program grants
that require different frequencies of
reporting. While a reporting schedule can vary
across programs, recipients are required to
report at least annually and must satisfy the
requirements for progress reporting under 2
CFR §200.329. Some programs may ask
recipients to report more frequently, either
semi-annually or quarterly. In these instances,
only those programs requiring more frequent
reports would need to be reported on as
specified in the terms and conditions of the
award; the other programs included in the
PPG would provide updates in an annual
progress report that covers all programs in
the PPG.
PPG TEMPLATE
OCIR developed a work plan and reporting
template that can be used to facilitate work
plan negotiation, creation, and progress
reports. This template includes the required
essential elements identified in GP111-03. The
template also contains additional (optional)
data fields which may be included at the
discretion of all participating federal and state
partners.
As a best practice and in accordance with GPI
11-03. the Regions should ensure that their
work plans align with the three Essential
Elements in the work plans. These Essential
Elements are:
1. Strategic Plan Goal
2. Strategic Plan Objective
3. Work plan Commitments (including the
negotiated timeframe for commitments to
be achieved)
The template provides a standardized list of
work plan components, which is intended to
create greater consistency in reporting of the
PPG activities and results. This template may
also be used for mid-year and end-of year
reporting by recipients to record progress of
meeting work plan commitments. To obtain a
copy of the template, please contact your
regional NEPPS Coordinator and Project
Officer.
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JOINT EVALUATION
As required bv40 CFR§35.115. PPG
performance is assessed by reviewing
reported outputs and outcomes according to
an agreed upon joint evaluation process. EPA
and the states develop a joint evaluation
process that is intended to analyze and report
progress on accomplishments under the work
plan. A description of the evaluation process
and a reporting schedule must be included in
the work plan and the schedule must require
the recipient to report at least annually and
satisfy the requirements for progress
reporting.
The elements of the joint evaluation process
must provide for:
~ A discussion of accomplishments as
measured against work plan
commitments
~ A discussion of the cumulative
effectiveness of the work performed
under all work plan components
~ A discussion of existing and potential
problem areas; and
~ Suggestions for improvement, including,
where feasible, schedules for making
improvements.
The purpose of the joint evaluation process is
to assess progress in accomplishing the
commitments in a grant agreement. Joint
evaluations produce valuable performance
information to support state and EPA
program planning and decision making and
provide assurance that EPA and the recipient
are meeting their environmental program
responsibilities.
EPA and State Coordination
The basis for joint evaluations comes from a
variety of sources and may be achieved in a
variety of ways involving one or many
program reports about the commitments in
the work plan, including formal reports from
program data systems, informal and formal
program reviews, site visits, and most
important, ongoing EPA-state staff
relationships. In addition to the joint
evaluation process, other program specific
reviews may be used to complement and
inform the joint evaluation. These include
reviews of delegation and other program
requirements and may occur outside of the
time frame for the joint evaluation process.
The joint evaluation will reveal both progress
and possible shortfalls under the work plan.
Fiscal Accountability
PPG recipients must maintain accounting and
financial records which adequately identify
the use of federal funds and cost share for
PPG activities. These records should contain
relevant information such as obligations,
unobligated balances, outlays, expenditures,
and program income. Recipients track PPG
funds to the total effort or costs incurred for
the PPG work and draw down funds from the
PPG budgetary account for the federal share
of costs incurred.
Can changes be made to an
approved PPG work plan?
Yes, the regulations at 2 CFR §200.308 and 40
CFR §35.114 provide information on when
prior approval from the agency is necessary. A
best practice that is embedded in the terms
and conditions of a PPG award is for the
recipient to consult with their EPA Project
Officer (PO) before making a post-award
change to the work plan. Consulting the PO
will help the recipient determine whether
their proposed work plan change is significant
or not. If the PO determines the change is
significant, the recipient must work with the
EPA PO and Grant Specialist (GS) to create a
formal amendment to the PPG, to be
approved by EPA's GMO.
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Per the "Transfer of Funds" General Term and
Condition, the recipient will notify the EPA PO
and GS of any transfers of funds among direct
budget categories, programs, functions and
activities or transfers that change amounts
budgeted for indirect costs. If the PO
determines that a transfer of funds
significantly changes work plan commitments,
or involves an item of cost subject to a prior
approval requirement under 2 CFR §200.407.
the recipient must consult with the PO and
obtain approval by EPA's GMO prior to making
the transfer of funds. All transfers must be
reported in performance reports.
If the recipient and PO cannot agree on
whether a significant change to work plan
commitments will take place, the matter will
be elevated to the EPA approval official for the
assistance agreement and an appropriate
senior manager for the recipient for a
negotiated resolution. The recipient cannot
make the change until the matter is resolved.
If a negotiated resolution is not achieved the
EPA's GMO or other authorized official will
issue an Agency Decision under the 2 CFR Part
1500. Subpart E Dispute Procedures.
Can the period of performance for a
PPG be extended?
Yes. If the original project period for a PPG is
less than five years, and a recipient needs
more time to finish the work plan
commitments, they can request an extension.
The administrative terms and conditions of
each assistance agreement dictate where to
send requests for an extension. Typically,
requests for extensions are sent to the EPA
GS and PO.
EXTENSIONS BEYOND FIVE YEARS<
When necessary, PPG recipients can request
an extension to the period of performance
beyond five years. To request an extension,
recipients should work with their PO to
submit the request, which must include:
~ Grantee Name
~ Grant Number
~ Current and Proposed Budget/Project
Periods
~ Remaining Award Amount
~ A justification for the extension,
including pertinent background
information, a description of their
circumstances, and what the extension
will allow the recipient to do.
The PO will submit the extension request on
the recipient's behalf to the Office of Grants
and Debarment (OGD) for consideration,
following standard agency procedure. As a
best practice, PPG recipients that anticipate
needing an extension beyond five years
should notify their PO six months before their
project end date to ensure it is processed in
time.
What is the EPA Quality Program?
EPA organizations and non-EPA organizations
performing environmental information
operations funded by or on behalf of EPA are
required to participate in the EPA Agency-wide
Quality Program. EPA's Quality Program
supports EPA's mission to protect human
health and the environment and to ensure
environmental information operations
products and services are of known and
documented quality for their intended use(s).
Project-specific details of individual projects
are documented in a Quality Assurance
Project Plan (QAPP). Thus, the Quality
Management Plan (QMP) may be viewed as
the "umbrella" document under which
individual projects are conducted.
Requirements for QMPs can be found in EPA
OA/R-2. EPA Requirements for Quality
Management Plans. Please also contact your
sponsoring organization for additional
requirements for QMPs.
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The terms and conditions of the award will
specify a recipient's quality assurance
responsibilities. Any data collection that does
not follow quality assurance procedures is
unusable and therefore the costs must be
disallowed. For more information on EPA's
Quality Program, please visit
www.epa.gov/quality.
What is a Quality Management Plan
(QMP)?
A Quality Management Plan (QMP) describes
an organization's Quality Program. It
documents how an organization, structures
its Quality Program including descriptions of
its internal quality procedures for
implementing and assessing the effectiveness
of the program; criteria for and areas of
application; and roles, responsibilities, and
authorities. The QMP must also document all
technical activities to be performed under the
Quality Program and how the program will
integrate quality assurance (QA), quality
control (QC), and Quality Assurance Project
Plans (QAPP) into all its environmental
information operations.
What is a Quality Assurance Project
Plan (QAPP)?
A QAPP is a planning document related to a
project that describes in comprehensive detail
the necessary QA/QC requirements and other
technical activities that must be implemented
to ensure that the results of the work
performed will satisfy the stated performance
and acceptance criteria. It integrates all the
technical and quality aspects of the project in
order to provide a "blueprint" for obtaining
the type and quality of environmental
information needed for a specific decision or
use. All work performed or funded by EPA
that involves environmental information
operations must have an approved QAPP.
A QAPP is a post-award requirement that
needs to be completed and approved
before environmental information
operations are conducted. Environmental
information operations is a collective term
that encompasses the collection, production,
evaluation, or use of environmental
information by or for EPA and the design,
construction, operation, or application of
environmental technology. Additionally,
activities involving environmental information
operations in the grant work plan may not be
funded until the QAPP is approved.
Requirements for QAPPs can be found in EPA
OA/R-5, EPA Requirements for Quality Assurance
Project Plans. Please also contact your
sponsoring organization for additional
requirements for QAPPs.
What is the difference between a
QMP and a QAPP?
A QMP is a document that describes a quality
program in terms of the organizational
structure, policy and procedures, functional
responsibilities of management and staff,
lines of authority, and required interfaces for
those planning, implementing, documenting,
and assessing all activities conducted. A QAPP
is a document that describes the necessary
quality assurance, quality control, and other
technical activities that must be implemented
to ensure that the results of the work
performed will satisfy the stated performance
criteria. A QMP documents the overall
organization/program whereas a QAPP
documents project-specific information.
Usually, a quality program is documented
once (and updated on a regular basis), but the
quality assurance activities are documented
for each project.
How does a PPG recipient draw
down funds?
As required by 2 CFR §200.305(aV recipients
must only draw funds for the minimum
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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 five business days of the drawdown will
materially comply with this requirement.
Excess funds drawn down not meeting this
requirement should be returned to EPA. More
information on receiving assistance
agreement payments can be found here on
EPA's website.
PPG recipients do not need to account for
PPG funds in accordance with the funds'
original environmental program sources; they
need only account for total PPG expenditures.
When drawdowns are made, they are charged
proportionately to each source of funds in the
PPG.
If funds remain after all work is
complete, what can a recipient use
those funds on?
If funds remain on the grant after all work
plan commitments have been accomplished,
PPG recipients may use those remaining
funds for additional activities that fall within
the scope of work. Recipients must contact
their PO to confirm proposed activities fall
within the scope of work before proceeding.
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Section IV: Closeout f(M
What does closeout mean?
Closeout refers to the systematic process EPA
uses to determine that a recipient has
completed all the required work under a grant
and to confirm that all applicable financial and
administrative requirements have been met.
Most grants follow the closeout procedures
that are outlined in the Office of Management
and Budget's (OMB) Uniform Administrative
Requirements. Cost Principles, and Audit
Requirements for Federal Awards regulations,
located at 2 CFR Part 200. In addition, EPA
grant policy requires all grants to be closed as
soon as possible prior to the end of the
calendar year following the project end
date(s):
~ 90 days before the project expiration,
the Agency Finance Center sends a
reminder to the grant recipient with
closeout procedures and requirements
~ No later than 120 days after the project
is complete, the grant recipient should
submit a final Federal Financial Report
(FFR) to the Agency Finance Center
~ Grant recipient should also submit a
Final Technical Report for EPA review
and approval
~ The PPG PO must complete the PO
certification form and return to the EPA
Grants Office
What is the process for closeout of
a PPG?
About 90 days before the PPG expires, EPA's
Research Triangle Park Finance Center
(RTPFC) will send a letter to remind the
recipient about the approaching end date and
explain the grant closeout requirements.
Under federal grant regulations as noted in 2
CFR §200.344. grants must be closed out
within 120 days of the end of the
performance period, meaning all final
progress and federal financial reports have
been submitted. More information and
training modules can be found on EPA's
website. Module 6, as depicted below, offers
insight on closing out a grant.
Module 6
Reviews guidelines and information about
closing out an EPA grant in accordance with
EPA's grant regulations and the terms and
conditions of the award.
Approximately 60 minutes \ Launch
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Program-Specific Requirements
There are program-specific requirements that do not apply to program funds when they are
included in a PPG. The following provides examples, but is not an exhaustive list, of program-specific
requirements that do not apply to PPGs:
~ 35.268(c): Administrative costs in the form of salaries, overhead, or indirect costs for services
provided and charged against activities and programs carried out with these funds shall not
exceed 10 percent of the funds the State receives in any fiscal year. The cost of
implementing enforcement and regulatory activities, education, training, technical
assistance, demonstration projects, and technology transfer programs are not subject to this
limitation.
~ 35.272: Recipients must use the lead-based paint program funding in a way that
complements any related assistance they receive from other federal sources for lead-based
paint activities.
~ 35.298(c): The costs of radon measurement equipment or devices (see § 35.290(b)(1)(iv)) and
demonstration of radon mitigation, methods, and technologies (see § 35.290(b)(1)(ix)) shall
not, in the aggregate, exceed 50 percent of a State's radon grant award in a fiscal year.
~ 35.298(d): The costs of general overhead and program administration (see § 35.290(b)(1)(vii))
of a State Indoor Radon grant shall not exceed 25 percent of the amount of a State's Indoor
Radon Grant in a fiscal year.
~ 35.298(e): A State may use funds for financial assistance to persons only to the extent such
assistance is related to demonstration projects or the purchase and analysis of radon
measurement devices.
While 40 CFR §35.134 states that §35.298(g) does not apply to PPGs, EPA has a class exception in
place that requires recipients of State Indoor Radon Grant (SIRG) funds to maintain and make
available to the public, a list of firms and individuals in the State that have received a passing rating
under the EPA proficiency rating program, regardless of whether those funds are in a standalone
SIRG award or a PPG.
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Appendix A: Glossary of Terms
Allotment: EPA's calculation of the funds that may be available to an eligible recipient for an
environmental program grant. An allotment is not an entitlement.
Consolidated Grant: A single grant made to a recipient consolidating funds from more than one
environmental grant program. After the award is made, recipients must account for grant funds in
accordance with the funds' original environmental program sources. Consolidated grants are not
Performance Partnership Grants. See § 35.109 Consolidated grants.
Environmental program: A program for which EPA awards grants under authorities listed in 40 CFR
§35.101. The grants are subject to the requirements of 40 CFR Part 35 Subpart A.
Funding period: The timeframe specified in the grant agreement during which the recipient may
expend or obligate funds for the purposes set forth in the agreement.
Outcome: The environmental result, effect, or consequence that will occur from carrying out an
environmental program or activity that is related to an environmental or programmatic goal or
objective. Outcomes must be quantitative, and they may not necessarily be achievable during a
grant funding period.
Output: An environmental activity or effort and associated work products related to an
environmental goal or objective that will be produced or provided over a period of time or by a
specified date. Outputs may be quantitative or qualitative but must be measurable during a grant
funding period. See "outcome."
National Program Guidance: Guidance issued by EPA's National Program Managers for
establishing and maintaining effective environmental programs. This guidance establishes national
goals, objectives, and priorities as well as the core performance measures and other information to
be used in monitoring progress. The guidance may also set out specific environmental strategies,
criteria for evaluating programs, and other elements of program implementation.
Performance Partnership Agreement: A negotiated agreement signed by the EPA Regional
Administrator and an appropriate official of a State agency and designated as a Performance
Partnership Agreement. Such agreements typically set out jointly developed goals, objectives, and
priorities; the strategies to be used in meeting them; the roles and responsibilities of the State and
EPA; and the measures to be used in assessing progress. A Performance Partnership Agreement
may be used as all or part of a work plan for a grant if it meets the requirements for a work plan set
out in § 35.107.
Performance Partnership Grant: A single grant combining funds from more than one
environmental program. A Performance Partnership Grant may provide for administrative savings
or programmatic flexibility to direct grant resources where they are most needed to address public
health and environmental priorities (see also 40 CFR §35.130). Each Performance Partnership Grant
has a single, integrated budget and recipients do not need to account for grant funds in accordance
with the funds' original environmental program sources.
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Pre-award costs: Pre-award costs, as defined in 2 CFR §200.458. are those incurred prior to the
effective date of the Federal award or subaward directly pursuant to the negotiation and in
anticipation of the Federal award where such costs are necessary for efficient and timely
performance of the scope of work. Such costs are allowable only to the extent that they would have
been allowable if incurred after the date of the Federal award and only with the written approval of
the Federal awarding agency. If charged to the award, these costs must be charged to the initial
budget period of the award, unless otherwise specified by the Federal awarding agency or pass-
through entity.
Per 2 CFR §1500.9. EPA award recipients may incur allowable project costs 90 calendar days before
the Federal awarding agency makes the Federal award. Expenses more than 90 calendar days pre-
award require prior approval of EPA. All costs incurred before EPA makes the award are at the
recipient's risk. EPA is under no obligation to reimburse such costs if for any reason the recipient
does not receive a Federal award or if the Federal award is less than anticipated and inadequate to
cover such costs.
Work plan: The document which identifies how and when the applicant will use funds from
environmental program grants and is the basis for management and evaluation of performance
under the grant agreement to produce specific outputs and outcomes (see 40 CFR §35.107).
The work plan must be consistent with applicable federal statutes; regulations; circulars; executive
orders; and EPA delegations, approvals, or authorizations.
Work plan commitments: The outputs and outcomes associated with each work plan component,
as established in the grant agreement.
Work plan component: A negotiated set or group of work plan commitments established in the
grant agreement. A work plan may have one or more work plan components.
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Appendix B: Frequently Used Acronyms
CAA
Clean Air Act
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
CFDA
Catalog of Federal Domestic Assistance
CFR
Code of Federal Regulations
CEP
Continuing Environmental Program
CWA
Clean Water Act
ECOS
Environmental Council of the States
FFR
Federal Financial Report
FIFRA
Federal Insecticide, Fungicide and Rodenticide Act
GMO
Grants Management Official
GPI
Grants Policy Issuance
GPRA
Government Performance and Results Act
GS
Grant Specialist
MOE
Maintenance of Effort
MPG
Multipurpose Grant
NEPPS
National Environmental Performance Partnership System
NPM
National Program Manager
OCFO
Office of the Chief Financial Officer
OCIR
Office of Congressional and Intergovernmental Relations
OGD
Office of Grants and Debarment
OMB
Office of Management and Budget
PO
Project Officer
PPA
Performance Partnership Agreement
PPG
Performance Partnership Grant
PRC
Program Resource Code
RA
Regional Administrator
SDWA
Safe Drinking Water Act
SWDA
Solid Waste Disposal Act
STAG
State and Tribal Assistance Grant
TPC
Total Project Costs
TSCA
Toxic Substances Control Act
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