Managing Your Grants

Managing Your Grants Betty Barton & Seema Rao

Award Offer • Review the award document • Project Manager • Budget/Project Period Date • Review the Terms and Conditions • EPA Participation • MBE/WBE • Reimbursement Limitation • New Single Audit Requirement • http://harvester.census.gov/fac/ • Reporting Requirements • Comply with the terms and conditions on the award offer

Award Offer • Sign the agreement and send it back to EPA Grants Specialist within 21 days • Cannot drawdown funds if countersigned copy is not received by EPA • Cannot Initiate any other funding actions or amendments • Retain a copy of the agreement in your grant file • Contact either the Grants Specialist or the Project Officer if you have any questions or concerns

Award Offer • Inform the EPA project officer if problems arise that could jeopardize the completion of the project • Delays due to change in Contractor • Turnover of Employees • Change in Key Personnel

Payments and Financial Reporting • Assistance Agreement Payment Process • Award signed by EPA award official • Recipient signs the award • Funds are made available to Recipient

Payments and Financial Reporting • Automated Standard Application for Payments (ASAP) • http://www.asap.gov • Office of the Chief Financial Officer • http://www.epa.gov/ocfo/finservices/grants.htm • Las Vegas Finance Center Point of Contact • Rheinhardt.sharen@epa.gov

Payments and Financial Reporting • Benefits of ASAP • One time enrollment • Greater Flexibility • Real Time Trsansaction

Federal Cash Transactions Report • Federal Cash Transaction Report, SF 272 • Due Semiannually for periods ending Dec. 31 and June 30 • Due no more than 15 days after end of reporting period

Financial Status Report • Financial Status Report (FSR) SF 269 • Due 90 days after end of budget period • Short Form SF 269A used to closeout grant/cooperative agreement without program income • http://www.whitehouse.gov/omb/grants/sf269a.pdf • Long Form SF 269 used to closeout grant/cooperative agreement with Program Income • http://www.whitehouse.gov/omb/grants/sf269a.pdf • If grant period is more than I year, then the Interim FSR is due annually • Note: Include EPA In-Kind in total outlays or in remarks; Include Non-Recurrent costs in remarks or on a separate sheet

Total Program Income Used Program Income Used as Cost Share or Matching Program Income Realized

DBE Rule • The new DBE rule became effective May 27, 2008 • Renamed as the Disadvantaged Business Enterprise Program • Only applicable to EPA financial assistance agreements that have procurement

Major Changes to DBE • Major Changes: • Certifications – new rule requires MBE/WBE to be certified either by the Small Business Administration or by a State or by other federal agency • Six Good Faith Efforts – EPA has combined the Six Positive Efforts under 40 CFR 30.44 and Six Affirmative Steps under 40 CFR 31.36 and renamed them as Six Good Faith Efforts • Contract Administration Requirement – pertains to Bait and Switch • Negotiation of Fair Share Goals • Recordkeeping and Reporting Requirement – reports that were due quarterly now due semi-annually

DBE Reporting • CEP grants (40 CFR Part 35) – Annual Reporting • Project grants – Semi Annual Reporting

Six Good Faith Efforts

MBE/WBE Reporting • Negative Reports Required • Final Report due within 90 days after the grant period ends • Grant cannot be closed until all the DBE reports are submitted to EPA • Failure to submit the reports can trigger enforcement action • New DBE Coordinator: Charles Hayes 404-562-8377 Hayes.charles@epa.gov

Continuing versus Project Grants

Applicable Regulations • Section 105 • 40 CFR Part 35, Continuing Environmental Programs • 40 CFR Part 31, Uniform Reqts for state and local agencies. • PM, NATTS, Special Projects • 40 CFR Part 31, Uniform Reqts for all EPA grants to state and local agencies.

Continuing Resolutions • When EPA doesn’t have a budget for the current FY. • Timing and amount of funds to be provided is unknown. • Increased workload for everyone. . • EPA’s priority under CRs is S/L continuing programs.

Program Timelines – §105 • 105 • New 2-year agreements begin 10/1/09. • Draft workplans and straw allocations. • FY 10+FY 11 applications due 9/1/09. • Except PPGs.

Program Timelines - PPGs Alabama Georgia Mississippi Tennessee

PM2.5 • Current grants began 4/1/08 and are being extended to 3/31/10. • All on same cycle for ease of monitoring all grant balances and identifying funds that can be swept. NATTS • Current grants began 7/1/08 and are being increased and extended to 6/30/10. • All on same cycle for ease of monitoring all grant balances and identifying funds that can be swept.

Grant Balances • Feds always in search of unneeded funds. • Is the allocation too high? • Are you drawing funds “just in time?” • New Unliquidated Obligations Procedures • 180 days without drawing $$ = huge fire drill. • To deobligate your balance or not??? • Extensive documentation.

Changes • Workplan • Budget • Equipment • Program Income • Key Contacts

Changes to Workplan • Email EPA Technical Project Officer with cc: to EPA Admin Project Officer to initiate changes. • What do you want to change and why? • Not because you have unspent funds you want to use.

Changes to Budget (40 CFR 31.30) • Cumulative changes of 10% or more across direct object classes require amendments. • (salary, fringe, travel, supplies, contractual, other) • Dollar amount of funds being shifted divided by total approved budget. • Supplemental funding. • Unanticipated program income. • Not because you have unspent funds you want to try and use.

Changes to Equipment • All equipment must be specifically justified and approved by EPA. • Initial budget as part of the workplan & grant award. • Or revised budget. • Federal definition? Or your agency’s? • Lease versus purchase? • EPA monitors equipment part of your budget.

Key Contacts • Very important. • Submit updates to Admin Project Officer with copy to EPA Grant Specialist.

Questions?

Managing Your Grants