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ACING AN AUDIT: MANAGING YOUR RLF GRANT FILE Audio 866-299-3188 Code: 202 566 2773. EPA Rlf webinar. October 31, 2013. ( Section A )- Acing an Audit: Grants File Management-R4 RLF PO Perspective ( Section B )- Acing an Audit: Grants File Management-EPA R4 RLF Grantee’s Perspective.
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ACING AN AUDIT: MANAGING YOUR RLF GRANT FILE Audio 866-299-3188 Code: 202 566 2773 EPA Rlf webinar October 31, 2013
(Section A)- Acing an Audit: Grants File Management-R4 RLF PO Perspective • (Section B)- Acing an Audit: Grants File Management-EPA R4 RLF Grantee’s Perspective Purpose of Presentation
Section (a) Rlf grants Management
Get Organized • RLF PO • Overseeing and monitoring the RLF Grant CA, and • Ensuring all financial and environmental cleanups requirements are met • Best “First” Approach • Setting up Six Part Folder
We wear Three hats: • PO Lead • Grants Lead • Technical Lead Region 4 RLF PO’s
Pre-Award Documents - PART 1 • Post-Award Documents - PART 2 • Progress Reports/Deliverables -PART 3 • Post-Award Monitoring Doc’s - PART 4 • Correspondences (Internal/External) - PART 5 • Brownfields Proposal Information-PART 6 Six Part Folder
PART 1- (Pre-Award) Checklist • Grant Application/Workplan • Workplan Comments/Approval • CN/FR/Cost Analysis • Competition Documents, etc.
PART 2- (Post-Award) Checklist • Signed Award Agreement with T&C’s • Change Requests to CA/Amendments • Closeout Documents/Memos
PART 3- (Progress Reports/Deliverables) Checklist LEGEND: 1/ Measuring Success/Tracking Documents 2/ Program Related Documents 3/ Cleanup Planning Documents
PART 4- (Post award monitoring Doc’s) Checklist • Baseline Monitoring Reports • Advance Monitoring Reports (Including Davis Bacon Compliance) • Semi annual Docs (MBE/WBE Rpts) • Annual Rpts (FFR)
PART 5- (Correspondences) Checklist • Emails/Letters • Faxes • Hand Written Notes, Memos, Etc.
PART 6- (Brownfields Proposal info) Checklist • Original Proposal • Congratulatory Letter • Fact Sheet
Section (B) RLF Grants Management
Webinar October 31, 2013 RLF Grants Management
Grantee Files RLF Loan Program Checklist (TCRPC)
Five part file system: • Proposal • Award • Program • Administrative Record / Project • Audit RLF Checklist
Contains: • Original EPA Grant Proposal • List of Brownfield Sites • Project Partners Proposal File
Contains: • EPA Grant Application • EPA-Approved Workplan • Signed Cooperative Agreement • Detailed project budget by expense categories • Project Timeline Award File
Contains: RLF Loan Program Materials: • Loan Policies and Procedures Plan • Marketing Plan with Collateral Materials • RLF Loan/Subgrant Application Forms • Loan/Subgrant Agreements • Site Access Agreement • Partner MOUs • EPA Property Profile Form Program Manager Materials: • Sample Quarterly Report Template • Financial Report Template • MBE/WBE Reports • RFQ Process Documentation • List of approved consultants • Team contact list • Consultant contact list • DOL Wage Determination, including interviews and certified payrolls Program File
Contains: • Brownfield Site Information (Legal, designation, Brownfield Site Rehabilitation Agreement (BSRA), etc) • ABCA • Assessment Reports • QAPP • Public Involvement Plan • RLF Match (Grantee and/or Loan or Subgrantee) • Qualified Environmental Professional • Cleanup Budget • Cleanup Contract • Cleanup Contractor Insurance • Loan/Grant Commitment Letter • Loan/Grant Agreement • Site Photos (Before and After) Administrative Record/Project File
Contains: • Written Policies and Procedures for: Procurements with respect to purchases, goods and services, consultant contracts and sub-awards. Audit File
Cost Share: • Cost share can be met by cooperative agreement recipient and/or loan recipient • If borne by loan recipient, the loan application should reflect local match Program Considerations
Administrative Costs: • Only eligible programmatic costs can be reimbursed by EPA • Administrative costs are not allowed • Other funds to consider to offset programmatic expenses include: • Other federal grants such as: • EDA District Planning Grants / Public Works Grants • HUD Community Planning Challenge Grants Program Considerations
ACRES/Financial Reports: • Update ACRES on a regular basis but especially after site milestones: • Completion of Phase I ESA/Phase II ESA • Completion of Site Assessment Report • Receipt of site closure order/letter from your state department of environmental protection/regulation • Consultants hired to complete assessments and/or site cleanup should be required to update ACRES for your agency • Agency program manager should review ACRES update after input by Consultant and request corrections, if needed • Financial Reports: • File once a year, program manager completes with finance manager Program Considerations
Contact Information • Greg Vaday • Economic Development Coordinator • Treasure Coast Regional Planning Council • (772) 221-4060 • Email: gvaday@tcrpc.org • Website: www.tcrpc.org
Webinar October 31, 2013 RLF Grants Management
Recommend 6 part file folder Site Specific RLF File
Application EPA Property Profile Form (WAM) Legal Property Description Assessment Reports Brownfields Agreement (if applicable) Final Remedial Action Plan ABCA 30-day Public Review Notice QAPP Public Information Plan ESA Consultation SHPO Consultation • Match • Davis Bacon Wage Rates • Qualified Environmental Professional (QEP) • Cleanup Budget • Cleanup Contract • Contractor Insurance • Loan/Grant Commitment Letter • Loan/Grant Agreement • Promissory Note • Photos Checklist
News Releases • ABCA • Remedial Action Plan • Community Involvement Plan (CIP) • Photos • Name & contact information of spokesperson for the project • Brownfields Agreement (if applicable) • Personal financial information- Not required* Administrative Record Contents
Please run the below ad one time on (date) in the NON-LEGAL SECTION of the Classifieds. Place a border around the ad and bold the lead lines. The ad should be created in the most economical size. Please bill to Sunshine Ventures, LLC, reference should be EPA Brownfields. Analysis of Brownfields Cleanup Alternatives (ABCA) and other documents for the Sunshine Ventures, LLC Project can be viewed at: Downtown Library Annex 123 Main Street Anytown, USA Questions and comments concerning the plan should be directed to Sam Jones, Sunshine Ventures, LLC 987 First Street Anytown, USA Phone: (101) 987-6543 Sample Forms- 30 Day Public Review
Sunshine Ventures, LLC – Community Involvement Plan for Sunshine Ventures Brownfields Cleanup Project • Overview of Project • Spokesperson & Administrative Record • Site Description & History • Community Involvement • Key Community Contacts • Local and elected officials • Media contacts and meeting places • Use the EPA template! Sample Forms- Community Involvement Plan- CIP
Mr. Joe Jones US Fish & Wildlife Our agency (name) plans to use grant funds from the Environmental Protection Agency (EPA) to lend for Brownfields remediation activities at property located at _________ , North Carolina. The intended reuse of the property is _________________________________________. The scope of work consists of ____________________________. Please comment on this project as soon as possible concerning its possible impact on endangered species in the area. If you have questions or require additional information, please contact me at 101- 234-5678 or _(email)_________________________. A location and site map is included for your reference. Thank you for your time and cooperation. ESA Consultation Sample Letter
To: State Historic Preservation Office (or equivalent) Our agency intends to use grant funds from the Environmental Protection Agency to lend for Brownfields cleanup activities at (site address). Under the terms of our Brownfields grant, we are required to investigate through the appropriate state office what, if any, adverse impact our project activities may have on historic properties. We have researched the available history of this property and the adjacent properties, and we are of the opinion that our project activities would have no adverse impact on historic properties whatsoever. We are formally requesting that your office investigate this matter and provide us with written communication relative to your position. Concurrence that assessment activities at this time will not have any effect on historic preservation in the area is appreciated. Please feel free to contact me if there is any additional information that we can provide to aid in your determination. (continued) SHPO Consultation Letter Sample
Brief description of the site, including a description of the physical site characteristics such as vegetation, slope, the presence of any structures, and a brief history of the development of the site, if known. This could include such things as if the site was built on imported fill, or filled and graded. Information in your files or reports as to whether the site or any part of it is listed on, or eligible for listing on, the National Register of Historic Places, and/or an Indian Reservation. Please include any correspondence with your State Historic Preservation Officer (SHPO). Activity Information: provide EPA details of the kinds of activities that will occur, where they will occur, and what care will be taken to minimize any potential impacts. If historic tax credits are part of the funding, the borrower will have necessary documentation. SHPO Consultation Letter Sample (2)
Based upon the information supplied in your loan request for additional funding, the Loan Review Board has approved your request for a loan of $xxxxx. According to our internal policies, this loan will be made from a grant from the Environmental Protection Agency (EPA) Revolving Loan Fund Program. The loan term shall be based on a thirty-year term with a 5-year full maturity rate. The interest rate shall be xxx percent (x%) fixed. Principal and interest are accrued and deferred until no later than July 1, 2013. Beginning July 1, 2013, monthly payments shall be in the amount of $xxx with the balance of the loan payable in full on July 1, 2018. Further, this loan offer is subject to the following additional terms and conditions: The RBI RLF funds shall be used to pay for cleanup planning activities and for asbestos remediation activities at 505 Summer Hill Road, Anytown, USA. Mr. Sam Jones will provide his unconditional personal guarantee and will provide a title policy for the property. Current business casualty/hazard insurance shall be maintained on Sunshine Ventures, LLC, in an amount sufficient to cover the total outstanding debt, with (Grantor- your name) named as loss payee. All closing costs and recoding fees are the responsibility of the borrowers and shall be paid at the time of closing. We are pleased to be able to support this exciting project. Sample Commitment Letter
Task 1: Community Involvement Task 2 Establish RLF and Grant Program Task 3 Operate RLF and Grant Program Task 4: Market RLF and Grant Programs Task 5: Cleanup & Redevelopment Planning Task 6 Applicant Screening Task 7 Other: Approximately 1.2% of total funds is allocated and needed for task overages and/or unforeseen and unplanned budgetary needs. Task 8 Loans and Grants Match Report Sample
Match= money, labor, material or services from a non-federal source. • Require the borrower to provide match. • Traditional financing to support the cleanup. • Non-profits can document time spent on the project (payroll, letter from finance office). Finding Match
Section II Section I Application Financials Legal Description of Property Executive Summary (project) • Assessment reports • Remedial Action Plan • ABCA • 30 day review • QAPP • ESA Consultation • SHPO Consultation • Community Involvement Plan • Brownfields Agreement * Inside Cover • Checklist File Folders- Just a Suggestion!
Section II Section I Application Financials Legal Description of Property Executive Summary (project) • Assessment reports • Remedial Action Plan • ABCA • 30 day review • QAPP • ESA Consultation • SHPO Consultation • Community Involvement Plan • Brownfields Agreement * Inside Cover • Checklist File Folders- Just a Suggestion!
Section IV Section III All funding commitments Sources & Uses of Funds Deed of Trust Promissory Note Personal Guarantees* UCC Forms* • Davis Bacon Wage Rates • Employee Interview Forms • Payroll Reports Section V • QEP Procurement Files • Cleanup Budget • Cleanup Contract • Contractor Insurance Section VI • Invoices • Requests for Reimbursement • Backup Documents File Contents
Maintain records for at least 3-10 years after submission of the final expenditure report. • Keep all records of claims until resolved. • Obtain written approval from EPA prior to destroying any records. • If you operate the fund following closeout- KEEP the Records! • Negotiate the requirements with EPA.; they have access to these. • RLF grant records maintained by recipients are not subject to the Federal Freedom of Information Act, 5 U.S.C. § 552. • Unless other federal, state, or local law applies, recipients are not required to permit public access to their records. Records Retention
ACRES- new information should be entered when you make a new loan or subgrant. • Update when you pay an invoice, or • Update prior to preparing your quarterly reports. • Financial reports- done through our finance office; send match report to them. • LOSRC is a Regional Planning and Development Commission, organized pursuant to the NC General Statutes 158-8, et seq. and 153A-391, enabling LOSRC to operate a RLF Program. Miscellaneous “Stuff”
Contact Kate O’Hara Senior Planner / BF Program Manager Land-of-Sky Regional Council 339 New Leicester Hwy, Suite 140, Asheville, NC 28806 (828) 251-7454 kate@landofsky.org