Tribal Historic Preservation Office Program and Annual Grants Training Fiscal Year 2014

1. Tribal Historic Preservation Office Program and Annual Grants Training Fiscal Year 2014

2. Division Chief Contacts HPG Division, Chief Hampton Tucker National Park Service 1201 I (Eye) St. NW Stop 2256, 6th Fl. Washington, DC 20005 202-354-2067 (T) 202-371-1794 (F) Hampton_Tucker@nps.gov THPO Program, Chief James Bird National Park Service 1201 I (Eye) St. NW Stop 2256, 6th Fl. Washington, DC 20005 202-354-1837 (T) 202-371-1794 (F) James_Bird@nps.gov

3. National Partnership Agreement Between the Tribe and the NPS Tribal Historic Preservation Officer Program

4. THPO/NPSPartnership Agreement The Tribe and NPS enter into Partnership in the National Program of Historic Preservation. In accordance with Section 101(d) (2) (B) of the National Historic Preservation Act (NHPA), the Tribe designates a THPO as the official to administer the Tribal Historic Preservation program. Subsequently, the THPOs are the official NPS contact for the THPO agreement and the grant agreement.

5. THPO/NPS Partnership Agreement • Under the Partnership agreement, the Tribe must submit: • 1. A proposed Workplan at the start of each fiscal year. • An Annual Program Report that include: • a) A Significant Preservation Accomplishments Report • b) A Grants Product Summary Report. • Annual program reports are required even if no grant • funding agreement is in effect.

6. Yearly Workplan Must Include: • 1. Number of properties expected to be added to inventory. • 2. Number of Section 106 undertakings expected to be • reviewed or consulted. • 3. Proposed preservation education activities. • 4. Other activities that will be paid for through the Federal funds.

7. Annual Significant Accomplishments Report • The annual Significant Preservation Accomplishments Report must include a brief discussion of 3 to 5 of the Tribe’s significant accomplishments or "success stories" that resulted from the Fiscal Year’s HPF grant assistance.

8. Annual Program Report • The Grants Product Summary Form is used to report detailed statistics regarding: • NHPA Section 106 Compliance Reviews • National Register Nominations • Areas/Properties Surveyed • Educational Activities • Other Consultations

9. Annual Program Report • Chapter 6 of the Historic Preservation Fund (HPF) Manual contains an explanation and details about eligible and ineligible program activities to ensure accurate reporting. • The HPF Manual can be viewed or downloaded from the NPS THPO Grant Website: • http://www.nps.gov/history/thpo/grants.html(link on the right-hand side.

10. Partnership Agreement Termination • Either party may terminate the partnership agreement. • If NPS moves to terminate the grant because the Tribe has not carried out its assumed responsibilities, it must first provide the Tribe an opportunity to correct any deficiencies.

11. THPO Annual Fiscal Year HPF Operations Grant Program

12. Grant Fiscal Contacts Ginger Carter, Primary Contact Grant Management Specialist 202-513-7233 (T) Ginger_Carter@nps.gov Madeline Konz Grant Management Specialist 202-354-2064 (T) Madeline_Konz@nps.gov Address and fax number: National Park Service 1201 I (Eye) St. NW Stop 2256, 6th Fl. Washington, DC 20005 202-371-1794 (F)

13. Statistics FY2013 – 142 THPO shared $7,867,323 in Historic Preservation Funding. FY2014 – Expected number of THPOs is 150, Expected reduction of 8% from 2012 levels if sequester holds. Over $215,000 of FY2011 THPO funds were recaptured because THPO did not/were unable to expend funds in time ($103,350 recaptured in time to re-award to Heritage Preservation Projects).

14. Funding Application Requirements • Applications for yearly operational funding (apportionment funding) must include: • 1. The proposed Workplan • 2. A standard SF424 Federal application package, which will be reviewed in the next portion of this presentation.

15. Funding Application Requirements • THPOs must submit a separate funding application each yearif they wish to receive their apportioned share of the Congressionally-appropriated FY HPF funds. • If a THPO intends to refuse funding support, he/she must forward a statement for the record early on so that those funds can be redistributed to other THPOs. Otherwise, the funds will be recaptured by the US Treasury and cannot be used by NPS or other THPOs.

16. Grant Agreements - 2 Year Life THPO grants run for 2 yearsand have a start date of October 1 of the fiscal year under which the funds are appropriated by Congress (regardless of when the grant agreement is written/signed). Grants are awarded every year. This means, THPOs can have two active grants at any point. One will be in its first year the other in its second year.

17. Application Checklist A full application package includes: • SF424, Application for Federal Assistance • SF424A, Budget for Non-Construction Programs • SF424B, Non-Construction Assurances • SF424C, Budget Construction Programs • SF424D, Construction Assurances • Annual Workplan

18. SAM/ASAP/Grants.gov Registration Grantees must submit the funding application through www.grants.gov. To apply on Grants.gov, Tribes must be registered in: • www.sam.gov – Federal Vendor Registry • www.asap.gov – Federal Payment System • www.grants.gov– Federal Application System Enrolling in all 3 systems can take several weeks, therefore new THPOs should begin enrollment as early as possible and should complete registering in systems in the order shown above (however, ASAP and grants.gov registration can be done simultaneously).

19. THPO Grant Application Process 1) THPO submits application through www.grants.gov. 2) NPS creates the grant agreement and emails a copy of the grant to THPO. The grant is now active. No counter-signature from THPO is needed on the agreement; THPO acceptance of grant is confirmed by Tribe drawing down funds from its ASAP grant account. 3) Funding is available in the THPO’s ASAP account within 24 hours of the THPO receiving the grant agreement.

20. SF424A Non-Construction Budget Form, Section B Column 1 (Administration costs) + Line J (indirect costs) may not total more than 25% of total budget (see red arrows) Budget must be broken out into 3 columns, separating Administration, Operations and Contractual expenses

21. Administration Costs (Column 1) Costs incurred when accomplishing activity directly pertinent to budget formation and execution, personnel management, finance, property management, equal opportunity and other “overhead” functions not directly attributable to specific program areas but specific to the HPF grant.

22. Sample Administration Costs • Preparation of Personnel Payroll • Audits • Collection, storage, and retrieval of management information related to central administrative control • Administrative and support services or equipment needed for or related to the above

23. Operating Costs (Column 2) Costs applied to a specific program area activity described in Chapter 6 of the Historic Preservation Fund Manual that contribute to the accomplishments of the THPO responsibilities.

24. Sample Operating Costs • Personnel costs for staff performing tasks related to THPO activities/projects/goals • Equipment/supplies needed for eligible THPO projects • Travel expenses for THPO program meetings/conferences

25. Subgrants /Contracts (Column 3) This column is where the costs of subgrants and/or contracts for work related to the THPO grant are listed.

26. Budget Categories Personnel - Direct employees of the Tribe, staff, or Elders. Consultant/Contractor – Those providing professional advice or services on the basis of a written agreement for a fee, including those providing professional advice or services.

27. Budget Categories Supplies: Includes items costing less than $5,000. Equipment: Includes items costing $5,000 or more per unit. Requires NPS approval prior to purchase. *Equipment requires on-going reporting requirements.

28. Budget Categories Indirect Costs - Costs incurred for a common or joint purpose benefiting more than one cost objective, and not readily assignable to the HPF grant without effort disproportionate to the results achieved.

29. Indirect Costs (IDC) Rate Agreement Each THPOs indirect costs cover a different set of expenses. What is included in the IDC is determined and stated in the IDC agreement. The THPO must have an executed IDC covering the FY to which it’s charging indirect costs for these costs to be allowable.

30. Budget Categories Other - This category includes anything that does not fit into any other category. If the majority of your costs fall into “other” you must add an explanation of what is included in these costs.

31. (Un)Allowable Costs Chapters 6 and 13 of HPF Manual – contains detail information on allowable and unallowable costs. Costs must be reasonable and defendable.

32. Common Unallowable Costs • Curation of artifacts after the grant end date • Entertainment and Alcohol, most food • Honoraria (stipends to elders allowed) • Lobbying/fundraising • Mitigation expenses • NAGPRA activities • Indirect Costs if no current IDC in place • Travel expenses beyond Federal per diem rates

33. Annual Reports: Fiscal THPOs receiving grant funding must submit an SF425, Federal Financial Report, along with their Annual Accomplishments Report and Grants Product Summary Report to show the status of their expenditures. The SF425 must show expenditures and obligations incurred as of the December 31st (15 months after the grant’s start date)and are due to NPS by the following January 31).

34. Reimbursements Reduce Review – All THPOs are on reduced review status, meaning that they may draw down reimbursements from their ASASP payment account as necessary without prior NPS approval, unless they are deemed to be a high risk grantee.

35. Reimbursements High Risk GranteeStatus – NPS will place a THPO on High Risk status if the THPO fails to comply with the conditions of the grant agreement, but it must first provide the Tribe an opportunity to refute or correct any deficiencies or problems identified by NPS. High Risk Grantees must get prior approval from NPS before being able to draw down funds through the ASAP payment system.

36. Grant Expiration and Close-Out Final Expenditures - All funds must be expended or obligated in contracts or purchase orders by the end date of grant – September 30th. No grant extensions allowed. Final Payment Drawdowns and/or payment requests must be completed within 90 days (by December 31st ) after the expiration date of September 30th.

37. Grant Expiration and Close-Out To close out a grant, a THPO must submit the following reports by the January 31 following the grant end date: a) Final Budget - A final Non-Construction, showing actual expenses, must be submitted on-line to NPS on an SF424a (and SF424c Construction Budget if applicable) by January 31st following the end date of the grant. b) Final SF425, A final Federal Financial Report.

38. Audits All grantees who expend more than $500,000 of Federal funds (combined from all sources) in a single fiscal year must complete a Single Agency Audit. A completed SF-SAC and Single Agency Audit reporting package must be submitted electronically to the Federal Audit Clearinghouse within 30 days after receipt of the auditor's report or 9 months after the end of the THPO's fiscal year, whichever is earlier. l

39. Federal Grant Laws Read your Grant Agreement Refer to the HPF Grant Manual Refer to Federal OMB Circulars

40. Federal Funding Accountability and Transparency Act (FFATA) Beginning if FY 2013, THPOs must enter all subawards (this does not include contracts for program work) of $25,000 or more, into the FFATA Subaward Reporting System (FSRS) within 30 days of award. https://www.fsrs.gov/

41. Federal Grants Law: Competition Federal laws require that all contracts and purchases be competitively priced and selected. Sole sourcing is only allow with special written permission from NPS.

42. Federal Grants Law: Bank Account Federal law does not prevent a THPO from keeping Federal grant funds in a bank account with other funds; however, if combined with other funds, the grantee must be able to prove in a court of law that the Federal funds were used only for their intended purpose. It is highly recommended that Federal grant funds be kept in a separate account from other funds.

43. Federal Grants Law: Equipment Items costing $5,000 or more per unit are considered equipment. Grantees must submit a Request for Equipment to NPS for approval prior to purchasing equipment, anAnnual Tangible Property Report each year to document the current value of all equipment purchased with HPF funds, and aTangible Property Disposition Request, to NPS for disposition instructions when the grantee no longer needs/wants/can use the piece of equipment.

44. Federal Grants Law: NPS Grant Acknowledgement All publications, videos, websites, reports, documents or other material produced with Federal grant funds must contain the NPS acknowledgement of Federal Assistance and the Federal Non-Discrimination Statement.

45. Federal Grants: Training Classes in Federal Grants Administration and Grants Law are available from: • Kiva Institute (nation-wide, Indian owned) • Management Concepts (nation-wide) • Graduate School USA (most classes in Washington DC)

46. THPO Grants Forms/Information Information regarding grant requirements and reporting are available from the THPO Program and THPO Grants Websites: http://www.nps.gov/history/thpo/grants.html