Fulfilling EPA Grant Requirements Environmental Protection Agency Phillip

Fulfilling EPA Grant Requirements Environmental Protection Agency Phillip Schindel, Associate Award Official Ariadne Goerke, Attorney Advisor, OGC 1

Congratulations! It’s A Grant! 2

Congratulations! It’s A Grant! � What is the big picture for grant requirements? � What is the framework for grants management? � What are some particular concerns? � What do we do about them? � What do YOU want to cover? 3

Congratulations! It’s A Grant! � What is it? It’s a Gift With Strings 4

Congratulations! It’s A Grant! Statute Regulation Executive Order OMB Circular TC 5

Specific Strings Attached Statute Regulation Executive Order OMB Circular TC Brownfield Administrative Cost Prohibition 6

Specific Strings Attached � Financial Management Systems 7

Specific Strings Attached: Financial Management Systems Personnel Procurement Accounting System Travel Property 8

Post-Award Concerns � Slow Progress � Missing Reports � Use of Funds Outside the Workplan � Lack of Adherence to Terms & Conditions � Drawdown of Funds either Ahead or Behind What Is Described in Progress Reports 9

The Case of… The Missing Reports 10

Resolving Post-Award Concerns: Basic Problems � Minor Negotiation � Changes �Time �Money �Workplan Modification � Followup Actions 11

Resolving Post-Award Concerns: Massive Problems � Performance Issues � Misuse of Funds � EPA site visit disclosures � Audit problems 12

The Case of… The Site Visit 13

• Late/Untimely reports • Lack of documentation • Inadequate monitoring of sub -recipients • Inadequate time/effort reports • Inadequate reports • Co-mingling of funds • Excess cash on hand • Unallowable costs • Inappropriate changes • Conflicts of Interest Prevention Top 10 PSA on Audits • Understand Conditions • Check with EPA PO/GS • Get it in writing • “Paperwork” is Proof • Keep accounting records • Draw funds for immediate needs only • Communicate early and often 14

Resolving Post-Award Concerns: Remedies � High Risk/Reimbursement � Withhold Funds � Order Work to Cease Until Deficiencies are Corrected � Require Repayment � Terminate or Annul � Refer to SDD 15

Resolving Post-Award Concerns: Misuse of Funds ◦ I had to go on a long honeymoon in Italy and couldn’t pay for it myself. ◦ My Project Officer told me to spend it, so I did. ◦ I needed new clothes! 16

The Case of… The Conflicted Interests � EPA provided grant funds for school bus diesel retrofits � State Grant Manager solicited bids � A new company made a proposal to subcontract to several known and reputable companies 17

The Case of… The Conflicted Interests � Buses started breaking down � State Grant Manager started avoiding work � The couple fled the country � They’re back now. 18

Resolving Post-Award Concerns: Remedies � High Risk/Reimbursement � Withhold Funds � Order Work to Cease Until Deficiencies are Corrected � Require Repayment � Terminate or Annul � Refer to SDD 19

What’s the Moral of This Training? � Communicate � Don’t be late � It’s not free money � But it’s still great! 20

Resources Administrative Requirements OMB Circular A-89 Catalog of Federal Domestic Assistance OMB Circular A-102 Grants and Cooperative Agreements With State and Local Governments OMB Circular A-110, Relocated to 2 CFR, Part 215 Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations 21

Resources Cost Principles OMB Circular A-21, Relocated to 2 CFR, Part 220 Cost Principles for Educational Institutions OMB Circular A-87, Relocated to 2 CFR, Part 225 Cost Principles for State, Local, and Indian Tribal Organizations OMB Circular A-122, Relocated to 2 CFR, Part 230 Cost Principles for Non-Profit Organizations 22

Resources Audit Requirements OMB Circular A-133 Audits of States, Local Governments, and Non-Profit Organizations 23

Questions? Statute Regulation Executive OMB Order Circular TC Personnel Procurement Accounting System Travel Property 24

Thank You � If you have any questions, please feel free to contact us at: � Schindel. Phillip@epa. gov , (202) 564 -5293 � Goerke. Ariadne@epa. gov , (202) 564 -5471 25