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Airports Division Eastern Region. Grant Closeout Guidance. 33 rd Annual Airports Conference. Patricia Henn, AIP/PFC Program Manager. March 4, 2010. Why do we need to discuss Grant Closeouts?. Trends in Grant Workload FAA Internal Goals Impacts to Sponsors and Consultants
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Airports DivisionEastern Region Grant Closeout Guidance 33rd Annual Airports Conference Patricia Henn, AIP/PFC Program Manager March 4, 2010
Why do we need to discuss Grant Closeouts? • Trends in Grant Workload • FAA Internal Goals • Impacts to Sponsors and Consultants • Required by AIP Handbook 5100.38c Chapter 13 and Title 49 CFR Part 18 What is the Grant Closeout process? • Work Completion Requirements • Administrative Requirements • Financial Requirements • Final Project Report and • Other Considerations
Why? Trends in Grant Workload • Open Grants as of 9/30/2009 • Nationally = 6,981 • Eastern Region = 609 • Our overall grant workload is increasing… • Nationally Grants Issued in 2009 = 3,324 Grants Closed in 2009 = 2,131 • Eastern Region Grants Issued in 2009 = 364 Grants Closed in 2009 = 310 • Number of Open Grants from 2007 or Earlier = 281
Why? FAA Internal Goals • By September 30, 2010, closeout 95% of those grants issued for 2006 and prior years that are open on October 1, 2009, not including those covered by extraordinary or unusual circumstances (litigation, SBG, reimbursables, etc.) • Number of Open Grants that are 4 years or older as of October 1, 2009 =147 grants • 95% goal =138 grants (not includingextraordinary or unusual circumstances)
Why? Impacts to Sponsors & Consultants • Discretionary Funds Recovered from closed out grants are used to fund future change orders and grant amendments • Could Delay Future Grants….. ACIP Handbook Chapter 10 Section 4 Paragraph 1031b(5) PROJECT EVALUATION REPORT AND DEVELOPMENTANALYSIS (5) Status of Prior Grant(s). If there are any projects over three years old or that have had no draw down for the proceeding 18 months and have not been closed out, give reasons for delays and schedules established for closing the projects. The maximum time for an AIP project, from date of grant acceptance to financial completion, is four years. In the case of a multi-year project, the maximum time for completion is four years from the date of the final multi-year amendment.
Why? Reference Orders and Regulations FAA Order 5100.38C Airport Improvement Program Handbook http://www.faa.gov/airports_airtraffic/airports/resources/publications/ orders/media/aip_5100_38c.pdf Title 49 CFR Part 18 Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments Section 18.41 Financial Reporting and Section 18.50 Closeout http://www.dot.gov/ost/m60/grant/49cfr18.htm
What? Current National Guidance FAA Order 5100.38C AIP Handbook • Chapter 13 – Section 2 Grant Closeout Procedures • Work Completion Requirements • Administrative Requirements • Financial Requirements • Final Project Report
What? Work Completion Requirements FAA Order 5100.38C Airport Improvement Program Handbook Chapter 13 – Section 2 Grant Closeout Procedures Paragraph 1312 Work Completion Requirements • Planning. The conditions are met when the sponsor has completed the work elements identified in the program narrative and the FAA has reviewed and accepted the final report. • Land Acquisition. Conditions are met when the sponsor obtains satisfactory property interest in all parcels included in the grant description, has submitted adequate title evidence or appropriate certification for all the parcels, and the FAA Airports Office has accepted such evidence. • Equipment Acquisition. Conditions are met when the equipment is delivered, installed, and tested in accordance with approved plans and specifications. At the option of the FAA Airports Office, the FAA or the sponsor may make final inspection. • Construction. Conditions are met when all work items in the grant description have been completed in accordance with the approved or certified plans and specifications and the final inspection completed as stated in Paragraph 1220(f).
What? Administrative Requirements FAA Order 5100.38C AIP Handbook Chapter 13 – Section 2 Grant Closeout Procedures Paragraph 1313 Administrative Requirements • As-Built Plans. “As-built” plans or certification. • Exhibit A, Property Map. Revised “Exhibit A” if any changes were made from the one submitted with the project application; • Property Accountability. • Block Grants. Forward information to the region on airport projects as described in Paragraph 1097a.
What? Financial Requirements FAA Order 5100.38C AIP Handbook Chapter 13 – Section 2 Grant Closeout Procedures Paragraph 1314 Financial Requirements • Final Financial Report. The sponsor shall be required to submit a final financial report to the FAA in accordance with Title 49 CFR, Parts 18.41 and 18.50. This report is required even if the sponsor has already received payments equal to the maximum obligation of the United States stated in the grant agreement. For construction and non-construction projects, the final report shall be made on the form the sponsor normally uses to request payment (SF-270 or SF-271) in cases of reimbursement by Treasury check, or on SF-272 if the letter of credit has been used. The final financial report may also serve as the request for final payment when 100% progress payment has not been made or when an adjustment to the 100% progress payment is required. • We have moved from SF272 to SF425 - PGL 10-1 issued October 7, 2009
What? Financial Requirements continued 49 CFR Part 18 Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments • Section 18.41 Financial Reporting • Section 18.50 Closeout • General • Reports – Within 90 days after the expiration or termination of the grant, the grantee must submit all financial, performance, and other reports required as a condition of the grant. Upon request by the grantee, Federal agencies may extend this timeframe. • Cost adjustment – The Federal agency will, within 90 days after receipt of reports in paragraph (b) of this section, make upward or downward adjustments to the allowable costs. • Cash Adjustments
What? Final Project Report FAA Order 5100.38C AIP Handbook Chapter 13 – Section 2 Grant Closeout Procedures Paragraph 1315 Final Project Report • Preparation. After the requirements of Paragraphs 1312, 1313, and 1314 have been met, a final project review shall be made resulting in a final project report. The report shall contain information deemed necessary for any subsequent examination or evaluation of the project. • Approval of Final Project Report. The report will normally be prepared by the FAA project manager and be reviewed and approved by the Airports Division Manager. This authority may be delegated but must remain at one level higher than the project manager in the chain of command. This constitutes a routine element of program checks and balances as required by OMB Circular A-123.
What? Other Considerations FAA Order 5100.38C AIP Handbook Chapter 13 – Section 2 Grant Closeout Procedures Other Considerations • Special Conditions • Grant Descriptions • Change Order Approvals