california plc instructor workbook

Welcome-Instructor Notes

USFWS – Wildlife and Sport Fish Restoration Program 0 - 1 Information Management Branch - National Training Project Leaders Course 2008

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Enter Tab Number: 0

Display while participants are finding their seats.

Course Leader: Welcome to the Project Leaders Course. Instructor introduction and give brief job experience. Have regional representative or co-instructors introduce themselves. Are all accommodations satisfactory, any difficulties with travel or issues to be resolved? If so, please see the course coordinator. Thanks for being here and working with us.



Housekeeping: Location of restrooms, break area, telephones. Announcements / messages are posted on message board located in break area. Please turn off or put your cell phones and pagers on silent. Course Material:

• Everyone should have a course notebook. The notebook contains handouts that will be used in class.

• Every two people have a laptop that will be used to look up information in the Toolkit.

• We’ll be working in pairs and groups on exercises throughout the course. • Parking Lot – You may ask questions anytime during the course. If we

cannot immediately answer the question we will write it down and post it on the question parking lot. The question may be answered later in the course or if it isn’t we’ll get an answer as soon as possible.

• Everyone should have completed pre-course work, online courses and expectations survey.

• Evaluation Form –Tell participants at the end of the course there will be evaluation forms and we would like their feedback. Explain that these are important tools for improving future courses.



Ask participants to stand and give the following information: Name, Agency position, years of service and grant program.

Please open your notebook to Tab 1 and we’ll review the Agenda:

• Start & stop times. • Flexibility of break and lunch

schedules. • The course follows the grant

management process. We have scheduled breaks, but the schedule is flexible. Let us know if you need a break.

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Table of Contents

USFWS – Wildlife and Sport Fish Restoration Program Information Management Branch - National Training Project Leaders Course 2008

Agenda 1

Goals and Objectives 2

Grant Management Process 3

Compliance 4

Pre-Award: Project Statement Development and Review 5

Pre-Award: The Grant Application Package 6

Award: Notice of Award 7

Post Award: Implementation, Managing & Monitoring 8

Grant Closure 9

Post Closure: Ongoing Responsibilities 10

Handouts 12

Agenda

USFWS – Wildlife and Sport Fish Restoration Program Information Management Branch - National Training Project Leaders Course

Project Leaders Course Wildlife and Sport Fish Restoration Program

Information Management Branch - National Training State Department of Wildlife and Fisheries

Month # - #, 2008

Day, Month # MORNING SESSION 8:00 a.m. Welcome/Introductions/Getting Acquainted – Unit 1

Grant Management Process – Unit 2 Compliance Issues – Unit 3

LUNCH AFTERNOON SESSION

Pre- Award: Project Statement Development and Review – Unit 4 Pre- Award: The Grant Application Package – Unit 5 Wrap-Up 4:30 p.m. Adjourn Day, Month # MORNING SESSION 8:00 a.m. Review Day 1/Preveiw Day 2

Award: Notice of Award – Unit 6 Post Award: Grant Implementation, Reporting – Unit 7 Grant Closure – Unit 8

LUNCH

Agenda

USFWS – Wildlife and Sport Fish Restoration Program Information Management Branch - National Training Project Leaders Course

AFTERNOON SESSION

Grant Closure (Cont.) – Unit 8 Post-Closure – Unit 9

Parking Lot / Discussion Wrap-Up/Post Course Survey

4:30 p.m. Adjourn

Goals and Objectives

USFWS – Wildlife and Sport Fish Restoration Program 2 - 0.0 Information Management Branch - National Training Project Leaders Course 2008

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The purpose of training program is to provide a national training program to develop basic and specialized grants management knowledge and skills resulting in the consistent and sensible application of regulations, processes, and decisions in the grant programs administered by WSFR. As part of this course you were required to complete two online courses. These courses are always available on the website and can be used as a resource. The courses are updated as changes occur in the grant programs. Mention other courses/resources from National Training Program?

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Goals and Objectives Instructor Notes


The purpose of this course is to: Increase your “effectiveness” = increase knowledge, improve understanding, give you tools to help you find answers to your grant management questions. This course was cooperatively created through a planning process with National Training program, your agency, the Regional Office and with you through the pre-course expectations survey. Review course objectives. Reference pre-course survey and cover additional objectives.

Be sure that everyone understands and agrees to the objectives for the course. Are there are any questions on the objectives or what will be covered in the course? Some objectives were covered in online courses. We’ll continue to build on these in the course. Mention acronyms and glossary in the Toolkit: General Guidance > WSFR Program Glossary




Welcome to USFWS – Wildlife and Sport Fish Restoration Program’s (WSFR) National Training. The goal of the National Training Program is to:

Provide a systematic and ongoing national training program to develop basic and specialized grants management knowledge and skills that result in the consistent and sensible application of regulations, processes, and decisions in the grant programs administered by WSFR.

The purpose of the Project Leaders Course is to increase the effectiveness of project leaders in developing and managing projects funded through the grant programs.

Course Objectives

Increase Project Leaders knowledge, skills, and/or abilities in:

1. Compliance requirements, especially NEPA and Section 7;

2. Writing project statements (narratives);

3. Writing/submitting performance reports;

4. Communicating, and coordinating with individuals/agencies involved with WSFR grant programs;

5. General and specific grant program guidance;

6. Grant cost accounting processes.

Introduction to the Grants Management Process


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Introduction to the Grants Management Process Instructor Notes


Review topic objectives. Whether a grant program is a permanent/indefinite appropriation or an annual appropriation, apportioned by formula or competitive, the State makes the decision to participate in the program. The State is notified of available funding either by letter, via WSFR PROGRAM website or an announcement on grants.gov. Once the State decides to participate in a grant program they must complete a grant application package that complies with the program requirements. In our Advanced Course we go into more on how this funding is made available to the States/Territories and managing the program funds.




Objectives:

1. Become familiar with the grants management process.

2. Understand the cooperation, communication, and coordination required to support the grantee/Federal grant management system(s).

3. Describe the roles and responsibilities of grantee staff in the management of WSFR Program grants.

4. Describe the roles and responsibilities of federal staff in the management of WSFR Program grants.

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The first phase of the grants management process is the Pre-Award phase. The State or Grantee probably does some planning or research to find the grant funding or somehow determines there is a need that must be met or can be met with grant funds. Pre-Award: During this phase the grantee develops and submits the application package, may need to address ranking criteria if it is a competitive program, address compliance concerns such as eligibility matching requirements and other compliance issues. The RO reviews, coordinates/communicates with grantee, approves grant. Competitive grants are approved based on ranking and selection process. Award: Once decision is made to approve the grant is awarded. An award letter is sent to the grantee including the amount, terms and conditions, and any special conditions. Funds may also be obligated to the grant if available (depending on grant program). Post-Award: After awarded, work begins, payments requested/received, manage, monitor, modify grant (as needed), reporting, and compliance concerns. Close-Out: final reporting (performance and financial, work completed, grant closes, compliance concerns Notice that compliance happens during all phases of process (discuss in next unit). Compliance may be related to grant program or specific grant award (eligibility such as assent legislation, civil rights, etc.). Compliance responsibilities continue even after close out of a grant. These include compliance, ongoing monitoring and accountability. Could include monitoring land use, transfer of property, equipment, etc.



Grants Management Process

The grants management process follows the life cycle of a grant award. Various activities are performed during each phase of the process to collect, evaluate and document information to enable your agency to receive federal funds. Consider your roles and responsibilities in the context of the processes involved in applying for and managing WSFR Program grants throughout the life cycle of the grant. In addition consider the people that you will interact and communicate with to effectively manage WSFR Program grants. Notes:

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On page X-3 let’s take about 10 minutes to perform the activity on identifying roles and responsibilities in the grants management process. You may work individually or with a partner to complete the table. Using the toolkit look up the references: Section 9 of the Wildlife Restoration Act 50 CFR 80 522 FW 2 Read or skim each reference looking for specific or implied roles and responsibilities for managing grants. The tasks are listed for you in the table. From the references given determine if the Feds or Grantee (State) is responsible and what position in your organization or Federal office is specifically responsible. Debrief exercise discussing answers displayed in the instructor manual. Point out on the first task that understanding the grant programs is important to proposing a project that is eligible for funding under a grant program. This was part of the key elements in the E-Learning course on grant programs. Where do these tasks fit into the Grants Management Process? Any additional tasks to add from participants? Who in their agency (give name) performs these tasks? If they don’t know they need to find out when they return to their office. As we work through the grants management process think about where your role fits into the process and the people you might need to communicate with.



Identifying Grants Management Roles and Responsibilities

Work individually or with a partner. Using the Toolkit, lookup and read Section 9 of the Wildlife Restoration Act, 50 CFR 80 and 522 FW 2. Look for references to specific or implied roles and responsibilities for managing grants.

Exercise: Grant Management Roles and Responsibilities

Task Federal or Grantee? Who’s Involved?

Identify and propose projects eligible for grant funding

Grantee Agency Leadership, WSFR Coordinator and Project Leaders and Field Staff

Ensure eligibility of Grantee Federal WSFR grant reviewer, FA Regional Chief

Review and Approve Grant Proposal

Federal WSFR Program grant reviewer and FA Chief

Ensure compliance with Federal laws and regulations

Grantee and Federal

WSFR Program grant reviewer, Regional WSFR Chief, WSFR Coordinator, Agency Leadership, Project Leaders, ES Biologist,

Request reimbursement for grant expenditures

Grantee Agency Fiscal Staff

Write and submit performance report(s)

Grantee WSFR Coordinator – Project Leader

Monitor sub-grantee compliance

Grantee WSFR Coordinator – Project Leader – Agency Fiscal Staff

Accomplish the objectives of the project

Grantee WSFR Coordinator – Project Leader – Agency Fiscal Staff

Conduct audits for compliance with program guidance

Federal Grantee

DOI OIG (Contracted Auditor) Agency Independent Auditor, State Single Auditor, EEO

Ongoing monitoring of land use issues

Grantee Agency Leadership, WSFR Coordinator, Agency Fiscal Staff, Agency Real Estate Staff

Review policies and make recommendations for clarifications to USFWS Director

Both JTF – list of members on WSFR website

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WSFR website provides list of JTF members

http://wsfrprograms.fws.gov/Subpages/ Policy/JTF_members.htm Many people are involved on each side. As we work through the course we will take a look at the people involved in each part of the grants management process. We will also discuss the value of communication with everyone involved.



Learning Points

The Grants Management Process is a logically organized set of procedures to collect, evaluate, and document specific information to enable the flow of Federal grant funds to your agency.

The primary role/responsibility of the Grantee is to initiate and implement the grant.

The Federal role is to review and approve grants and to provide oversight of the program.

Many people, Federal and State, are involved in the grants management process.

Coordinators, project leaders and financial staff within the grantee organization have roles and responsibilities in the grants management process that require communication and cooperation to effectively and efficiently manage grants.

Effective communication among the Federal and grantee staff involved in the grants management process is essential for success.

An Overview of Compliance Issues


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An Overview of Compliance Issues Instructor Notes


Discuss the objectives. In this module we’ll begin with the phases of the grants management process and follow that for the remainder of the course. We’ll start with taking a look at the compliance issues that exist in the rules and regulations, and the various levels of compliance and specific issues affecting grant programs administered by WSFR Program. As you see from the graphic, compliance occurs throughout the process and some of the compliance requirements continue even after the grant is over. Some of the compliance requirements have specific documentation processes such as forms, certifications, etc., and some may need to be completed prior to applying for a grant or at the time of application. In other cases grantees agree to comply with the requirements. The compliance requirements may be reviewed during site visits, program reviews or audits. As we discuss the compliance requirements think about when you would need to address it in the process, the documentation and the people you need to communicate or coordinate with to meet the requirements.




Objectives:

1. Describe the different levels of legal responsibilities associated with the grant programs administered by Wildlife and Sport Fish Restoration Program.

2. Determine federal compliance issues that exist in addition to general grant administrative requirements and the enabling legislation.

3. Identify and discuss specific documentation requirements that exist for several compliance requirements.

4. Explain the purposes and general requirements of the Statement of Assurances.

5. Discuss the compliance requirements for various program and project types.

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Grant programs are enabled by Congress through authorizing legislation or Acts. In its enabling legislation each grant program has specific compliance and eligibility requirements. Recall from your pre-course work on WSFR Program grants the many compliance and eligibility requirements (considered key elements). Also, you may review the grant program worksheets. Compliance begins with the authorizing legislation and is found throughout the grants management process in complying with federal rules and regulations. Who are the eligible grantees? States and Territories. Tribal grants are administered by External Affairs with help from WSFR. This compliance determination occurs prior to the Pre-Award phase before an applicant can apply for the grant program. Recall some of the other requirements and mandates of programs administered by WSFR Program. These were reviewed in the key elements. These are probably ongoing monitoring issues throughout the GMP. SFR – FW/Marine split, assent legislation, aquatic education, boating access. WR – Hunter Ed Sec 4/10, assent legislation. SWG – Plan



Act Specific Compliance Requirements

Each grant program has specific compliance and eligibility requirements in its enabling legislation. As part of your pre-course work you completed the Review of Wildlife and Sport Fish Restoration Program grants online module, which highlighted many of the compliance and eligibility requirements.

• Purpose of the Grant Program

• Eligible Grantees

• Eligible / Ineligible Projects and Activities

• Spending Mandates, Matching Requirements, Funding Limitations

• Special Conditions

• Governing Guidance (CFR, Rules, etc.) Notes:

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In addition to enabling legislation all WSFR grant programs must comply with 43 CFR Part 12 – Admin, Audit & Cost Principles. And each grant program has a specific CFR that governs that program. If the program is new it may not have a CFR but instead will have final guidance published in the Federal Register until a CFR is written. While the Acts are the big picture, CFRs get more specific. The CFRs may reference other federal requirements, CFRs and/or OMB circulars. Assign participants to groups and assign each group a CFR or Final Program Guidance to review. Have participants describe their observations about the scope of the guidance contained in the regulation. Ask groups to share their observations point out some common compliance requirements. Follow up by asking if some of the same requirements found in the Acts were also found in the CFR/Program Guidance. Point out that the CFR/Policy Guidance is written from the Acts, same compliance requirements may be found in several places. Participants may see assurances requirement in all guidance, 80.21, 81.9, 84.50, 85.48, 86.55



Governing Regulations and Administrative Regulations

All grants administered by Wildlife and Sport Fish Restoration Program are governed by 43 CFR Part 12 Subpart C referred to as the Common Rule. This contains all of the Department of Interior Administrative, Audit and Cost Principle requirements for financial assistance programs. 43 CFR Part 12 incorporates OMB Circulars as well as guidance such as manuals issued by the agency administering the financial assistance program. In addition most grant programs are governed by federal regulations in the form of the Code of Federal Regulations (CFR) and/or Federal Acquisition Regulation (FAR). If a program is new it may not have a CFR but instead have final guidance published in the Federal Register. Using the Toolkit review the Federal Regulations (CFR/FAR or Final Program Guidance) assigned to your group. Review the section titles and list the type of compliance related guidance contained in the regulation. 1. 43 CFR 12 Subpart C

Financial & administrative, application forms, allowable costs, matching funds

program income, audits.

Pertains to all programs administered by WSFR. 2. 50 CFR 80

WR & SFR Programs. Administrative requirements, matching, mandates,

license certification requirements, responsibilities, reporting.

3. 50 CFR 81

Endangered Species – Sec 6. ESA, federal laws & assurances, coop

agreements with States

4. 50 CFR 84

National Coastal Wetlands. Eligibility, conditions, reporting

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Governing Regulations and Administrative Regulations (continued)

5. 50 CFR 85

CVA. Requirements for participation, record keeping, reporting, application,

cost share, allowable costs, fees collected.

6. 50 CFR 86

BIG. Ranking criteria, facilities, assurance statement.

7. LIP Guidance

25% matching, Sec 7/NEPA, land, floodplain.

8. SWG Guidance

Comply with 43 CFR 12, OMB A-87, A-133, A-102, NEPA, Sec 7, Plan by

10/1/05.

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In the guidance we just reviewed one of the compliance items referenced was the Statement of Assurances. The Statement of Assurances is submitted as part of the grant application package. It’s a standard form that is required, SF 424 B or SF 424 D, construction & non-construction. Most ROs allow one statement of assurances to be submitted annually for all SFR/WR/SWG grant programs. See 522 FW 1.3 B. Competitive grants may need to submit the assurances with each grant since those grants are usually nationally competitive. Check with RO.

What is a statement of assurances? It is a legal contract obligating your agency to abide by all applicable federal rules. If applying electronically the statement of assurances will be submitted electronically and signed electronically. Let’s take a look at the requirements on the statement of assurances. Assign table groups to summarize one of the following assurances: 1, 2, 3, 4, 6, 8, 11, 13.

You will notice that some of these assurances were also listed in the Act/Program Guidance and will also be listed in the Service Manual Chapters. Compliance requirements may be repeated or overlap in several different places. Assurance #7 (424B) refers Uniform Relocation same as Admin requirement in 523 FW 1. Assurance #8 (424B) Hatch Act is related to Lobbying restrictions in 43 CFR 18. Assurance #18 (424B) covers any other federal requirements. What happens if grantee does not comply? Funding would cease, expenditures would not be reimbursed, future grant funding at risk, audit findings. What triggers compliance? Accepting the federal funds.



Exercise: Statement of Assurances

Work as a group to review the Statement of Assurances. Use the Statement of Assurances forms found in the Toolkit (SF424B, SF424D). 1. Read the assurance that is assigned to your group and be prepared to give a

one sentence summary.

OMB Circular A-102 (c) (3) requires use of SF 424 D (Construction) for land

acquisition grants.

2. What happens if the grantee does not comply with the laws or regulations

listed on the Statement of Assurances?

Funding would cease, expenditures would not be reimbursed, future

Grant funding will be at risk, audit findings.

Statement of Assurances

50 CFR 80.21 Sport Fish and Wildlife Restoration 50 CFR 81.9 Endangered Species

50 CFR 84.50 Coastal Wetlands 50 CFR 85.48 Clean Vessel Act 50 CFR 86.55 Boating Infrastructure Grant Program

522 FW 1.3 B Administrative Requirements Federal Aid in Fish and Federal Aid in Wildlife Restoration (annual submission of one for all SFR/WR grants)

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We mentioned the Hatch Act and Lobbying

when we went over the Assurances #8. Federal funds cannot be used to lobby. However, State funds may be used to lobby for a particular grant. If the State does lobby for a particular grant then the State must disclose this information by using a Standard Form (SF) LLL. This must be submitted with the grant application. Until recently there was a certification form that had to be completed for lobbying, debarment/suspension (523 FW 1.2 D and 43 CFR 12.100-12.510) and Drug-Free Workplace (523 FW 1.2 D and 43 CFR 12.600-12.635). The form was DI-2010. It is no longer required.



Disclosure of Lobbying Activities

Federal funds cannot be used by the grantee or paid by the grantee to any person for influencing or attempting to influence an officer or employee of an agency, a Member of Congress, and officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement. Funds other than Federal funds may be used for lobbying. However, if any funds other than Federal funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the Federal contract, grant, loan, or cooperative agreement (currently being submitted), the grantee must complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying," in accordance with its instructions. Notes:

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Now we’ve looked at compliance in the Acts/Enabling Legislation, the CFR (Common Rule) and the CFR for the specific grant programs, the Statement of Assurances and the Lobbying disclosure forms that must be submitted with the grant application package. The next guidance we’ll be discussing is in the FW Service Manual Chapters. Part 523 FW 1, Compliance Requirements and Part 522 Chapters 3 through 15. These chapters apply to all FA grant programs. Have participants review 523 FW 1 Compliance Summary for overview of compliance requirements by category.

Debrief using slides showing 4 categories and items within each category. Non-discrimination Environmental Historic & Cultural preservation Administrative

Chapter 1 of Part 523 contains a summary of compliance. This does not include all compliance requirements. You can see that some of these items were also listed on the statement of Assurances. Would all of these Acts and Executive Orders apply to all types of projects? It depends on the specific type of work being performed or the type of project. However, you must consider all of them when applying for and managing your grant. Also, think about when you might need to consider them in the Grants Management Process. It could be at the time of application, or if you make a change to work being performed and should be monitored throughout the grant. Depending on the type of grant/project you’re working on it might require more documentation for some of the Acts/Orders we just reviewed. What about NEPA, Section 7, SHPO? What types of projects might be impacted by those Acts? Construction? We’ll talk more about NEPA and Section 7 processes and documentation in a few minutes.



Compliance Requirements Summary

Using the Toolkit review Service Manual Chapter 523 FW 1 Compliance Summary. Summarize the requirements by listing the four broad categories of compliance requirements shown in 523 FW 1.2.

1. Non-discrimination

2. Environmental – depending on work performed may require additional

consideration and documentation in grant application package.

NEPA/Section 7 documented in Project Statement. 3. Historic & Cultural Preservation - depending on work performed may

require additional consideration and documentation in grant

application package. Documented in Project Statement or letter. 4. Administrative – may require documentation such as program income

disposition, matching funds.

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The work being performed in the grant or the project type may have specific project dependent compliance that must be considered and documented in the grant application package or other phases of the grants management process. The FW Service Manual Part 522 includes a chapter for each project type. Split into groups, have each group review a chapter and provide info or do as class discussion exercise. Discussion Points: Permits - attachments ADA Cultural Resources NEPA/Section 7 NEPA and Section 7 must be documented in the Project Statement in enough detail for the grant reviewer to make determinations and complete documentation. (More on NEPA/Section 7 – if included in PLC).



Program and Project Dependant Compliance (522 FW 1.4 and 1.7)

Using the Toolkit review Service Manual Chapters in Part 522 Federal Aid Program Guidance and list the compliance requirements that should be considered for the project types or grant work being performed. Cite the references used and the phase of the grants management process the compliance should be addressed. 1. Grant to purchase land.

Chapter 6.7 A, B, C

2. Grant for construction of facilities.

Chapter 10

Uniform Relocation Assistance & Real Property Acquisition Policies Act of

1970, National Historic Preservation Act of 1966, Section 504 Rehabilitation

Act of 1973, NEPA, SHPO ADA, Coastal Zone, ES, Coastal Barriers.

3. Research grant.

Chapter 11

4. Coordination grant.

Chapter 3

Animal Welfare Act of 1985 (does not include fish),

Endangered Species Act, NEPA 5. Hunter Education grant.

Chapter 13

Civil Rights

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While all compliance requirements must be

met, you can see that some require specific documentation that are either submitted with the grant application or kept with the grant records. Proof of compliance may be required during audits. A grant application cannot be approved without the compliance issues being addressed and documented. We will continue to discuss compliance requirements throughout the grants management process.



Compliance Documentation

As a consequence of accepting Federal funds, States and other grantees must comply with all applicable Federal laws, regulations and policies. Compliance with some requirements must be documented with specific supporting documents and/or using specific processes. These documentation requirements will vary by program and/or project type. Other requirements are part of all phases within the grants management process. Check the Service Manual and other guidance documents for specific requirements.

Notes:

Information for projects allocated between programs, Boating Access,

Hunter Education, Aquatic Education along with matching.

Coastal States should provide an allocation of costs for projects having

both marine and freshwater fisheries benefits. Split is based on # of anglers

either from National Survey or a State’s own survey, see 50 CFR 80.23.

Assurances, permits, appraisals, NEPA, Endangered Species, State

process documents.

This may be called “Other Supporting Documents.”

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Review learning points.

More about NEPA/Section 7 or go to Pre-Award. Now that we have an idea of the compliance requirements that exist during the grant process, in the next module we’ll begin Pre-Award, actually looking at the documents and considerations when applying for a grant.



Learning Points

Compliance requirements are found in the enabling legislation, governing program guidance, administrative requirements and the Service Manual Chapters.

Compliance requirements must be addressed to receive funding for a grant.

Compliance requirements include administrative, environmental, historical and cultural and non-discrimination.

The Statement of Assurances ensures the reviewer the grantee is aware of the need for compliance with the laws and regulations listed on the assurance form.

A signed Statement of Assurances form is a legal contract obligating the grantee to abide by all applicable federal rules.

Compliance requirements will vary depending upon the grant program and project type.

Information must be included in project statement for WSFR staff to make compliance determinations for NEPA and Section 7 as well as any other compliance requirements.

National Environmental Policy Act

USFWS – Wildlife and Sport Fish Restoration Program 4a - 0.0 Information Management Branch – National Training Project Leaders Course 2008

Revised 03/03/2008 Filename: c:\documents and settings\dunbehagen\my documents\course_modules02-08\compliance\nepa.doc Enter Name of Course: Project Leaders Course 2008 Enter Tab Number: 4a Handouts: NEPA Process & Documentation chart

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National Environmental Policy Act Instructor Notes

USFWS – Wildlife and Sport Fish Restoration Program 4a - 1 Information Management Branch - National Training Project Leaders Course 2008


USFWS – Wildlife and Sport Fish Restoration Program 4a - 1 Information Management Branch – National Training Project Leaders Course 2008


Objectives:

1. Understand the NEPA documentation process.

2. Identify the issues that prevent using categorical exclusions.

3. Explain the steps involved in preparing an environmental assessment.

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NEPA, as part of the compliance process, is a safeguard for reviewing proposed Federal Actions and assessing the impact they will have on the human environment. Since approving a grant is a federal action, activities, jobs, etc. that are funded with Federal grant dollars must undergo NEPA scrutiny and documentation. WSFR is responsible for preparing the administrative record for complying with NEPA or requiring the preparation of additional environmental documents (EA or EIS) if needed. The NEPA Process & Documentation chart represents this decision making process. See handout. The State plays a key role in the NEPA process by providing adequate information and documentation for WSFR to make a decision and document NEPA compliance. No federal funds can be used on a project until a NEPA decision is made & documented. WSFR will use the information provided by the State in the project statement (part of application package) to gather information to review and evaluate the proposed work, the scope of the project, the impact on the human environment and any public controversy or interest that may be generated. Based on this review and evaluation a decision is made whether to Categorically Exclude the project or initiate further environmental reviews and decisions. Actions that can be categorically excluded fit within the Cat Ex lists if no extraordinary circumstances are triggered. Categorical exclusions are classes of actions which do not individually or cumulatively have a significant effect on the human environment. If a Categorical Exclusion is made WSFR will document it with the NEPA Compliance Checklist as the administrative record and the grant will be approved.



Complying with the National Environmental Policy Act (NEPA)

The purpose of the NEPA process is to consider detailed information concerning every significant environmental impact on the human environment, which is defined as the natural and physical environment and the relationship of people to the environment. Additionally, the process ensures the public plays a role in both the decision-making process and the implementation of that decision. Compliance with the NEPA process is relatively simple and unimposing for the majority of work proposed under grant programs administered by WSFR. However, the process does require that a specific set of logical steps be followed and documented to support conclusions about effects grant work will have on the human environment. The general flow for documenting the NEPA decision is depicted on the NEPA Process & Documentation chart in your workbook. Working through the NEPA decision making process requires evaluating several factors before implementing federally funded work projects.

NEPA Factors:

• Project Scope

• Potential for Significant Impact on the Human Environment

• Public Interest and/or Controversy Generated The effect of these factors determines which of the three documentation processes must be followed in complying with NEPA requirements. Adequate information must be provided in the project statement (approach) for the WSFR Regional Office to make a determination.

NEPA Compliance

Service Handbook

NEPA Guidance to States Participating in The Federal Aid Program

Director’s Orders

Director’s Order 127, National Environmental Policy Act Compliance Checklist

General Guidance

NEPA Reference Handbook (USFWS)

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Take a look at the guidance used in making a Cat X and review the sections. This will give you an idea of the type of information WSFR needs in the project statement to make a Cat X determination. DOI 516 DM 6 was replaced with 516 DM 8.5.



Reviewing Categorical Exclusions

Using the Toolkit review Director’s Orders – Rules – Policy – Interim Guidance>Final Rule>Categorical Exclusions, and answer the questions below. 1. Which section of the final rule contains the list of categorical exclusions?

1.4

2. Review each of the following sections, and list several categorical exclusions

for each.

General

Amendments, educational activities, not involving new construction or

major additions to existing facilities, purchase of real property, procedures.

Resource Management

Research, inventory, info collection, O&M, some construction to existing

facilities, prescribed burns, fire mgmt, stocking, minor changes

Permit and Regulatory Functions

Permits endangered & threatened species, ESA permits, special regs,

limited additional right of way use,

Recovery Plans

Issuance of recovery plans

Financial Assistance

Grants & cooperative agreements for planning or categorically excluded in

previous sections.

Revised 3/6/08



If the project involves new construction and/or other specific disruptions in the environment, it may require additional documentation prior to making a NEPA decision. The steps for continuing the process may require that an Environmental Assessment be conducted. An EA may take 3 to 6 months to prepare, then has to be reviewed/commented on by public. See handout. Depending on outcome an EIS may be required. This is a lengthy process that may take years and many staff hours. Remember that unlike ES (will discuss next) only Federal Actions are covered by NEPA. If you have to take this to the next step of EIS you may want to consider 100% State funding for those projects if they’re going to involve an EIS. If you are applying for Federal financial assistance or making changes in scope of work to an existing grant, enough information needs to be provided in the project statement concerning the environmental effects as necessary to satisfy WSFR requirements to comply with NEPA. States may want to review the NEPA Checklist for the elements WSFR is evaluating – Checklist can be found as Appendix G to DO #127. Review the learning points.



Learning Points

The NEPA process is assessing a project’s impact on the human environment.

Federal funds can not be used on a project until a NEPA decision is made and documented.

The three types of documentation processes are the NEPA checklist, Environmental Assessment, and Environmental Impact Statement.

The scope, potential for significant impact on the human environment, and the public interest and/or controversy of a project will determine the documentation process.

Section 7 of the Endangered Species Act

USFWS – Wildlife and Sport Fish Restoration Program 4b - 0.0 Information Management Branch – National Training Project Leaders Course 2008

Revised 03/03/08 Filename: c:\documents and settings\dunbehagen\my documents\course_modules02-08\compliance\section7.doc Enter Name of Course: Project Leaders Course 2008 Enter Tab Number: 4b Handouts: Section 7 Compliance chart

Revised 3/6/08

Section 7 of the Endangered Species Act Instructor Notes

USFWS – Wildlife and Sport Fish Restoration Program 4b - 1 Information Management Branch – National Training Project Leaders Course 2008

The Endangered Species Act applies to everyone, regardless of funding.




Objectives:

1. Determine the information needed in the project statement to evaluate the impact on listed, proposed to be listed, candidate species and/or critical habitat.

2. Discuss the importance of this information in the Section 7 evaluation process.

Revised 3/6/08



As part of the NEPA process (number 8 in the checklist) more specific documentation is required about the endangered species aspect of any federal project or grant and if it will have a specific effect on an endangered species or its critical habitat. Section 7 of Endangered Species Act is to ensure that there are no endangered or threatened species present or if present that the project will not impact the species. WSFR must document based on information provided by the State. Mention that the ES Consultation Handbook is in the Toolkit. Information must be included in the project statement or grant cannot be approved. Adverse actions may require more thorough consultations with FWS ES personnel. Establishing this record of action is important to the continuity of the grant if it comes under legal review. Review handout – Section 7 Compliance Process.



Reviewing Endangered Species Act Requirements

Using the Toolkit, review Service Manual Chapters>Part 523 Compliance Requirements>Chapter 1 Summary. Click on the link Endangered Species Act of 1973 listed under Section B Environmental Requirements. What are the requirements regarding endangered species for WSFR projects?

RD must ensure that WSFR Program projects are not likely to jeopardize the

continued existence of endangered or threatened species or result in the

destruction or adverse modification of critical habitat. For projects which may

affect an endangered or threatened species, either beneficially or adversely, a

formal Section 7 consultation is necessary. The State is required to name the

listed species and/or critical habitat included, list the name, description,

and location of the area, list the objectives of the action, and provide

an explanation of the impacts of the actions listed on a

Listed species or critical habitat. The Wildlife and Sport Fish Restoration Program Regional Offices work with regional endangered species staff and grantee coordinators to make determinations of impact and establish a record of action. The general decision making process is depicted by the Section 7 Compliance Process flow chart.

Section 7 of Endangered Species Act

Congressional Acts

Endangered Species Act

General Guidance

Endangered Species Consultation Handbook

FW 523 1.9 Fish and Wildlife Service Manual

Revised 3/6/08



Information must be included in the grant’s

project statement concerning impact of actions or the grant cannot be approved. Adverse actions may require more thorough consultations with FWS ES personnel. This is information that should be included in the project statement by the State.



Complying with Section 7 of the Endangered Species Act

Complying with Section 7 of the Endangered Species Act requires evaluation of impacts of action(s) on listed, proposed to be listed, candidate species/critical habitat. Identify Action: “Action(s)” represent either project(s) or job(s), depending on the specificity needed to adequately document impacts to federally endangered and/or threatened species/critical habitat. If a grant is comprised of several “action(s)” (e.g., projects covering habitat management, population manipulations, resource assessments, outreach, land acquisition, research, and surveys), then each project represents a distinct “action” requiring a separate description and recommendation. If a grant is comprised of one project or job (e.g., herpetological atlas), only that one action requires a description and recommendation. Describe Action(s) and Location: Provide a concise but complete description of the action, and include location of work. For example, several sport fish species indigenous to waters of the State are spawned, hatched, reared, and stocked out to restore or sustain populations. Recommendation: For grants with several action(s), identify a unique recommendation for each action; e.g., identify projects/jobs with land acquisition as “No Species Present” or “No Effect”, non-destructive data collection as “No Effect”, and Section 6 as “Not Likely to Adversely Affect”. No Species Present: Self-explanatory, this is the correct recommendation when no federally listed or candidate species/critical habitat within the action area. Species Present:

No Effect: List all federally listed species/critical habitat in the action area, and explain why action(s) has No Effect.

Is Not Likely to Adversely Affect: List all federally listed species/critical habitat in the action area, and explain rationale for recommendation by including the following information: (I) species status such as population trends or distribution in the action area, (ii)habitat status such as whether its critical or non-critical, species use it for breeding, migrating, or foraging, (iii) how will the action impact species/habitat (consider direct, indirect, interdependent, interrelated, and cumulative impacts).

Revised 3/6/08



Review learning points.



Learning Points

The NEPA process requires documenting the effect a project has on endangered species.

The Section 7 process supports the NEPA decision.

Establishing a record of action is important to the continuity of the grant if it comes under legal review.

Pre-Award: Developing and Reviewing the Project Statement


Revised 03/03/08 Filename: s:\federalaid\courses\ilt\plc2007\revised plc\workbook\5_projectstatement_detail.doc Enter Name of Course: Project Leaders Course 2008 Enter Tab Number: 5 Handouts: Example project statements

Revised 3/6/08

Pre-Award: Developing and Reviewing the Project Statement Instructor Notes

USFWS – Wildlife and Sport Fish Restoration Program 5 - 1 Information Management Branch – National Training Project Leaders Course 2008

Review objectives for topic. As you can see there are many issues that need to be considered when applying for a federal grant. Part of being successful in managing your grant is covering these issues up front and having checks and balances in place throughout the grant award. This begins in the pre-award phase when the applicant begins gathering the information and completing the documentation required in the grant application package that will be submitted to the RO. In this module we’ll start looking at the project statement, one of the documents required in the grant application package.

The project statement is probably the most important document in the package. It may also be called the project narrative.




Objectives:

1. Identify and explain the components of the project statement/narrative.

2. Determine if the proposal is substantial in character and design.

3. Determine if the project statement/ narrative meets minimum requirements.

4. Determine if enough information is included in project statement to satisfy NEPA and Section 7 compliance requirements.

Revised 3/6/08



The project statement or narrative identifies the need and describes the work to be accomplished. There’s not a standard format; however there are required elements described in the federal regulations. If submitting electronically this will be submitted as an attachment. Cover the elements of the project statement:

Need – Why? Evidence? How was it determined? Lays ground work for everything else. Objective – What will be accomplished by addressing Need? Don’t confuse with approach of how. Expected Results – Benefits to public Approach – How is this going to be accomplished? Location of work – Where? Estimated Cost - $$ Budget If it is a competitive grant there may be other criteria you wish to address in the project statement or narrative. You should review the guidance for the grant program you are applying for. Keep in mind, Project Statements should be clear and concise! You don’t want to throw everything into the project statement. More is not necessarily better, only if it is pertinent to the project. Now, let’s take a look at each element of a project statement in detail.



Definition of a Project Statement

A project statement or narrative identifies the need and describes the work to be done. It is required for each project to be funded in a grant. Grantees may use their own format for the project statement/narrative. Project statements must contain all elements required in the program guidance. Competitive grant programs contain additional requirements used to evaluate and rank grant applications. Specific program guidance should be reviewed for ranking criteria.

Required Elements of a Project Statement

A. Need ----- Why?

B. Objective ---- What?

C. Expected Results --- Benefits?

D. Approach --- How?

E. Location of Work --- Where?

F. Estimated Cost --- $$$

Project Statement

522 FW 1.3 Federal Aid Program Guidance 50 CFR Part

80.13 Administrative Requirements Federal Aid in Fish and Federal Aid in Wildlife Restoration

Policy / Program Guidance for specific grant program

Revised 3/6/08



Need - is the part of the project statement that lays the ground work or the rationale for under-taking the project. Why is the project being done? Why your agency is dealing with the problem or issue? The Need must be related to the program and eligible under the enabling legislation. It is important to identify and write a good need statement. All elements in the project statement must connect.

How was it determined or identified? What is driving the need? How does State identify need, how does it fit into State planning process? Agency has legal authority or mandate? Was need identified through public meetings? Nuisance reports from public? Evidence to support the need? Supply/demand? This should be documented with data collected, historical, geographic, quantitative, cultural, economic, factual or statistical. May want to add tables or data in appendixes instead of listing it in the need. Agency strategic plan? Give a clear and concise explanation of the need especially in competitive grants.

Objectives must relate to the need stated earlier. Objectives - Specify exactly what you hope to accomplish given the time, funding, and staff. Must relate to need – intended accomplishments during the grant period. Should be measurable or verifiable.

Time Bound – Specify a date everyone recognizes as the time frame the objective will be achieved. Objectives should be output / benefit oriented. Realistic – As to time, funds and personnel. Accomplishments must be measurable or verifiable to meet or solve the need. Don’t confuse with approach. Should be clear, concise, specific, measurable, attainable and realistic to address need. Be sure you are able to report accomplishments based on these objectives for reporting purposes. Think ahead!



Defining the Required Elements of a Project Statement

NEED

• Why is the project being undertaken?

• How does the identified need relate to the grant program?

• Describe the supply and demand aspects.

• What evidence is there about the need?

Notes:

Increase habitat – why? Not a good need. Protect & conserve species.

Build additional BA ramps – why? Provide access to an identified water body.

Is it for anglers to have access? How was it determined? Prescribed burns?

Provide X number of acres of habitat.

Easier to write measurable objectives & expected results tied to need.

OBJECTIVES

• What measurable or tangible accomplishments are going to be reached by the end of the grant period that will address the NEED(S)?

o Specify exactly what you hope to accomplish.

o Specify a date everyone recognizes as the time period in which it

will be accomplished.

o Output / Benefit Oriented

o Realistic given the time, funds and personnel

o Accomplishments must be measurable or verifiable.

Notes:

If need was to provide additional angler access – objective could be to build

a number of BA ramps that will provide X number of days of angler access or

Opportunities. Answer the need. Burns – to provide X number of acres of

habitat.

Revised 3/6/08



Spells out what benefits you expect from solving or addressing the need. Outcome to people using the resource What are the benefits of solving the need? How will the work benefit a variety of individual interests (stakeholders). Take into consideration the outcome requirements or overall success attributed to the project by accomplishing the objectives. How will it be measured? Increased use, economic, access, recreational opportunity?

Presents in detail exactly how you propose to: Pursue the work Methods you will employ Timelines you will follow How you will evaluate the results Project Leader Principle Researcher / Investigator Other Key” Staff Should allow anyone reviewing the proposal to make a judgment on the likely hood your proposal will result in meeting the objectives. The methodology that addresses how the objectives will be accomplished. This is the detail, procedures, timeline, key personnel and rationale for using a specific method, it must be scientifically sound. Describes how the project is expected to work to solve the stated problem. Should describe planned activities, staff & resources, how different aspects of the project will interrelate, where personnel are needed & purpose. You may want to include what will happen to the project beyond the funded grant period. The approach must contain enough detail to meet NEPA/Section 7 compliance. You may wish to detail this information out in a separate heading in the project statement. The RO must have adequate info to document and make NEPA/Sec 7 decisions.



Defining the Required Elements of a Project Statement (continued)

EXPECTED RESULTS

• What positive, quantifiable results and benefits will your work accomplish?

o Increased Access - How much, how measured and who will benefit?

o Increased Use…How Measured?

o Economic Impact…How Measured?

o Increased Recreational Opportunity…How Measured?

Notes:

Measured? National survey? State economic agency? Creel survey?

Vehicle counts, survey results, check stations?

Results may be used as ranking criteria for competitive grants. These should

be addressed in order to receive points.

APPROACH

• How will you reach the objective(s) in the time allotted?

o Specific procedures

o Schedules

o Key project staff functions

o Cooperators

Notes:

May include 3rd party agreements – local governments to build access sites.

The “how” will be used for compliance, especially with NEPA/Section 7.

Revised 3/6/08



Where will the work be done? Statewide Regional Management Area Specific Location Congressional District

Discuss elements of the “Estimated Cost” section of the project statement. Cost Categories vs Cost Centers (Activity Based) Total Project Costs Detail of Match Federal / State / Other Specify Federal program funding State’s fiscal staff should be consulted on developing cost estimates and what categories to employ. May want to check cost principles to see what is allowed, may be submitted by category such as personnel, travel, supplies or by activities or jobs. Must relate to the work and approach. Either in project statement or budget should show indirect costs, include if program income is expected and how it will be used. If projects are split between various subprograms (FW/M) this must also be identified including matching share. Show in-kind matching (if known). Be sure to address the ranking criteria if it is a competitive grant and show in the proper element.



Defining the Required Elements of a Project Statement (continued)

LOCATION

• Where will the work be done?

Notes:

Specific location – this may be needed for compliance issues, NEPA and

Section 7. If statewide is listed that is where Section 7 ES is applied.

ESTIMATED COST

• How much does it cost?

• Federal / Grantee Share

• Cost Detail…Cost Categories or Job Costs?

Notes:

List by category: Salaries, Supplies, Equipment or by Job 1, Job 2, etc.

Specify federal program funding, detail match, 3rd party or other funding

Provide enough info for grant specialist to determine substantiality in

character and design. Reasonable & necessary items are determined

during audit in compliance. This is bigger picture –

commensurate with project costs.

COMPLIANCE INFORMATION

Notes:

Compliance info may be included in approach & location, using checklist

or other form, or additional documents. For NEPA & Section 7 specifically

WSFR must be able to make determination based on information in

application and document for the administrative record. Grantee

must answer what, when, where, who, why, and how.

Revised 3/6/08



Competitive grants have different ranking criteria depending on the grant program. It is important to review the specific program guidance, understand the ranking criteria and write a clear and concise project statement / narrative addressing the criteria. WSFR staff review competitive programs using the same criteria in addition to the specific ranking criteria and special requirements in competitive grant program. Address Criteria Identify critical dates in the process Understand how ranking criteria effects your score Maximize non-Federal share Include partners Be sure package is complete. You may not have time to submit additional information.



Writing Successful Project Statements/Narratives

• Follow guidance carefully and be aware of critical dates

• Make it visually easy to read and to find required elements of project statement

• Address ranking criteria and understand how your application will be

evaluated against the criteria

• Maximize federal share by including partners and/or in-kind match. You may need to include documentation showing commitments made by partners.

• Be concise

• Professionally written – grammar, spelling, sentence structure and avoid

using jargon unless useful and necessary

• Be complete but limit number of pages, include appendices and attachments only as necessary

• Number the pages, use standard fonts and font sizes, omit fancy binders

and tabs

• Indicate if partial funding is acceptable (usually for competitive grants)

• Submit a complete grant package

• Communicate with the Regional Office Grant Specialist prior to and during grant application process.

Revised 3/6/08



Have students go to toolkit and read 50 CFR 80.13 Allow 3-5 minutes to complete Debrief by asking questions in workbook on Substantial in Character and Design.

§ 80.13 Substantiality in character and design. All projects proposed for funding under the Acts must be substantial in character and design. A substantial project (for fish and wildlife purposes) is one which: (a) Identifies and describes a need within the purposes of the relevant Act to be utilized; (b) Identifies the objectives to be accomplished based on the stated need; (c) Utilizes accepted fish and wildlife conservation and management principles, sound design, and appropriate procedures; and (d) Will yield benefits which are pertinent to the identified need at a level commensurate with project costs. In the Compliance module we reviewed 522 FW 1.4 and 1.7 and looked at specific chapters for project types. Point out that different types of projects or grants might have different requirements in order to make determination. Example: Construction project dealing with water control structures may require review of architectural and engineering plans by WSFR to show that design is appropriate. See FW Chapters on project types.



Substantial in Character and Design

Read 50 CFR 80.13 and be prepared to discuss substantiality in character and design. 1. Define substantial in character and design.

See 50 CFR 80.13 a – d. d may be the biggest issue. Grant reviewers

are familiar with big picture costs. Even though 50 CFR 80.13 is for WR/SFR

this same guidance is applied to all WSFR grant programs.

2. What documents are reviewed to determine if the grant application is

substantial in character and design?

Generally the project statement and budget information (estimated cost).

However, depending on the grant program and type of project other

documents may be reviewed as required in 522 FW 1.4 and 1.7 and

522 FW 3 through 15. 3. Who has ultimate responsibility to determine if a project is substantial in

character and design?

WSFR. Grantees decide how money is used but must document

substantiality of character and design to reasonable satisfaction of WSFR.

Notes:

Revised 3/6/08



Exercise Reviewing a Project Statement Instruct students to pullout their sample grant narrative. Lets turn to the Exercise in your workbook and complete questions. In this exercise we will critically review our grant narrative for compliance with the guidance on projects statements, determine whether the project is eligible for funding, if it is substantial in character and design and if it included enough information for WSFR-RO to make a determination and document NEPA/Section 7 compliance. You may work together we will debrief this exercise in 30 minutes. Please be prepared to discuss your answers. Question 7: Lead discussion of how this grant measures up to the requirements of “substantial in character and design” Refer to exercise section for debrief notes. Review good & bad project statement examples.



Exercise: Reviewing a Project Statement

Instructions: Using the handouts referenced by the instructor, answer the following questions:

1. Is the project statement consistent with the guidance found?

Need, Objectives, Expected Benefits / Results, Approach, Location, Cost,

and Key Personnel (FW 522 1.3 & 50 CFR Part 80.13) 2. Under which WSFR grant program is this project eligible for funding?

3. What is the identified need?

Is it clear and concise?

4. What evidence exists to support the need?

Is it clear WHY this work is needed? Does the narrative reference proof of

the need? How was proof measured?

5. Do the objectives relate to the identified needs?

Are objectives based on the stated need? Are the objectives measurable

or verifiable?

6. What are the expected results of the project?

To the extent feasible, provide quantified resource or public benefits

Revised 3/6/08



Debrief question # 12 using the following

criteria in addition to specific project type chapter. § 80.13 Substantiality in character and design. All projects proposed for funding under the Acts must be substantial in character and design. A substantial project (for fish and wildlife purposes) is one which: (a) Identifies and describes a need within the purposes of the relevant Act to be utilized; (b) Identifies the objectives to be accomplished based on the stated need; (c) Utilizes accepted fish and wildlife conservation and management principles, sound design, and appropriate procedures; and (d) Will yield benefits which are pertinent to the identified need at a level commensurate with project costs.



Exercise: Reviewing a Project Statement (continued)

7. How will the objectives be accomplished?

THE APPROACH – what are the steps, processes, or actions that will take

place to ensure the objectives will be accomplished? Compliance?

8. Does the project statement give specific and detailed information on the

activities, actions, species, and locations to determine and document compliance with NEPA and Section 7?

The answer depends on the example used in class. Approach and location

should contain the information needed on how, where, what, when, who,

and why. Also will this generate public controversy? What is the footprint

of the project and indirect impact. Discuss RO specific processes regarding

NEPA/Section 7. Could this be covered by a categorical exclusion? 9. Does this type of project require additional compliance or documentation?

Depends on example used. Have participants cite specific FW Chapter.

Remember our discussions during the compliance section. 10. What is the estimated cost of the project?

See budget sheet or estimated costs included in project statement.

Does the budget information include jobs, activities or object detail? 11. What is the location?

Location is important when documenting NEPA, Section 7, SHPO.

If statewide, can compliance for ES be met? 12. Is this project substantial in character and design?

Recall the 4 criteria for substantial in character and design.

Revised 3/6/08





Learning Points

The required elements of a project statement are need, objectives, expected benefits/results, approach, location, and cost.

Need must be a need relevant to the Act.

Objectives must be based on need.

Objectives must be verifiable and measurable.

The approach describes how you will reach the objective(s) in the time allotted.

Approach must include adequate information for WSFR Regional Office to document and make determinations for NEPA and Section 7.

Approach should include key personnel.

Project must use accepted conservation and management principles and appropriate procedures.

Benefits must be commensurate with project costs.

Different types of projects or grants may have different requirements in order to be “substantial in character and design.”

Understand and address ranking criteria when writing project statements or narratives for competitive grant programs.

Pre-Award: The Grant Application Package

USFWS – Wildlife and Sport Fish Restoration Program 6 - 0.0 Information Management Branch – National Training Project Leaders Course 2008

Revised 03/03/2008 Filename: c:\documents and settings\dunbehagen\my documents\course_modules02-08\preaward\plc-preaward.doc Enter Name of Course: Project Leaders Course 2008 Enter Tab Number: 6 Handouts: Example grant application package

Revised 3/6/08

Pre-Award: The Grant Application Package Instructor Notes

USFWS – Wildlife and Sport Fish Restoration Program 6 - 1 Information Management Branch - Training Program Project Leaders Course 2008

Review objectives for topic. Once the State has identified the need and decides to apply for a grant, the grant application package must be completed and submitted. The State decides whether to submit the package electronically or use paper forms. Currently no mandate exists to submit in one format or another. We know that we must submit the project statement in the grant package and the elements that must be included in it. Now we will identify the remaining documents that must be submitted in the grant application package.




Objectives:

1. Identify and explain the purpose of the various components of the grant application package.

2. Determine the need for inclusion of compliance and other supporting documents.

3. Discuss the estimated costs of the project.

Revised 3/6/08



In the following exercise we’re going to examine the documents submitted for our example grant assuming they were submitted using paper documents.

Debrief: In the exercise you used the FW Manual 522 FW 1Standards for Administrative and the CFR for the grant program – which is ......... If other grant program review CFR for specific grant. You will want to address additional ranking criteria for competitive grants or other requirements for applying, ES – coop agreement, SWG – plan, etc. Budget info to make substantial in character & design determination and to obligate funds by subprogram, SHPO, permits or other compliance issues must be addressed for any projects that will be funded. Additional project information may be included in application package to show subsequent years funding that will be needed but not funded in current grant period. May also have to include SF-LLL to disclose lobbying with funds other than federal. May see old forms in previous grant documents no longer required as of 10/1/06: DI-2010 Certification form, NEPA Checklist, Section 7 form



Examining the Grant Application Package

Use the Toolkit to review 522 FW 1 Standards for Administration in the Service Manual Chapters and the applicable CFR for grant program. Compare the example grant handouts to the description found in the guidance. Work with your tablemates and answer the following questions: 1. List the documents required in a grant application package. Cite the

references used.

Application for Wildlife and Sport Fish Restoration Program, Form SF 424

Project Statement

Budget Information or Budget Form

Statement of Assurances, Form SF 424B or SF 424D (annually for all grants)

State Process documents under E.O. 12372

Supporting documents depending on grant program & project type

Cite CFR for program – WR 50 CFR 80.11, additional documents from

FW Service Manual based on project type. Supporting documents

or information needed to meet compliance requirements. NEPA/Sec 7. 2. Are all of the necessary forms and documents included in the grant

application package (handouts)? Missing? Additional?

If participant says something is missing or extra ask them to cite reference

that supports that the document be included or excluded from the package.

Assurances may be submitted one time annually for all grant applications.

SF-LLL may be included if State is using State funds to lobby.

State Clearinghouse may be included if State has a SPOC.

NEPA/Section 7 information or documentation depending on regional

process. Depending on project type other documents may be included

SHPO, permits, etc. Budget document may also be included if costs are not

in project statement or use SF 424 A or C.

Revised 3/6/08





Examining the Grant Application Package (continued)

3. Is the applicant eligible to participate in this grant program?

Yes, since it is a state fish & wildlife agency. All applicants for

WSFR grant programs are State grantees.

4. Are there any mandates that must be met by the applicant to be able to

participate in this grant program?

For SFR/WR Assent legislation (agree to the provisions of the Act).

SWG requires CWS.

5. What are the consequences of submitting incomplete or incorrect

documents?

Incomplete or incorrect documents may result in approval delays,

possibly delaying implementation of the project until all correct

information is received. 6. Who is responsible for preparing and submitting the grant application

package?

State Project Managers, Coordinator, Biologist, Accountant

7. Who is responsible for reviewing and approving the grant application

package?

WSFR Coordinator, Federal staff biologists, Chief WSFR

Revised 3/6/08



Let’s identify and assemble the grant application package. After we identify these documents we’ll take a closer look at the critical information on the SF 424. To identify documents, have participants give handout number assigned to each document and briefly discuss. SF 424 – Various SF 424s in Toolkit & on grants.gov. Will discuss when we take a closer look at info on SF-424. SF 424 also includes assurances and budget forms. State may use their own version of budget form.

Project Statement – covered earlier Budget documents may be included in package. Estimated costs may be shown on project statement or on separate budget sheet. State may also choose to give information for subsequent years – previously submitted on a 5 year AWSFR. Budget info used to make substantial in character & design determination. Ask participants if they remember the compliance discussion from earlier in the day? Do we have any supporting documents included in our grant application package? Have we considered all the compliance issues associated with the grant program and project type? Statement of Assurances, Non-Construction/Construction (discussed in compliance) submitted annually NEPA Checklist and Section 7 documented in project statement. State Process Documents Clearinghouse – EO 12372 Intergovernmental Review corresponds with check box on SF 424. SPOC list on OMB website. http://www.whitehouse.gov/omb/grants/spoc.html Go through each type of compliance and ask participants if it has been considered. Some may be documented in pre-award phase others may need to be considered for future phases if/when grant is awarded and documented later in grants management process.



Assemble the Grant Application Package

Using handouts identify each in the block below.

Documents Handout #

SF - 424

Project Statement

Budget Information

Assurances

State Process Documents

Other Documents

Revised 3/6/08



Have participants pull out the example SF 424 to go over and answer questions. Purpose-standard form used by all applicants of federal assistance. Form captures all applicant information and may be submitted paper or electronic format. If using grants.gov and submitting electronically you must use application referenced for the announcement posted. Otherwise the State may use the core SF-424, mandatory SF-424 or the original/standard SF-424. Fillable forms are available in Toolkit or on grants.gov using Pure Edge forms (free software).

Focus on the information that is needed on the form not the form itself. The forms have few variances. Dates of all documents must be consistent. Submit to WSFR RO prior to expected start date. Pre-award must be requested and approved. Will discuss more on dates when we go over the grant award. The application may be for one year or multiple years – State decision. Dates and amounts shown on SF 424 will be what is reviewed and approved. Compliance must be met for time period and funding shown on SF 424. If WR/SFR grant program it may be approved subject to availability unless grantee wants to obligate entire amount and it is available. Grantee may choose to obligate a lower amount or year for year (if multi year) as apportionments are received. Competitive grant programs cover funding period and amount requested on SF 424. No option of funding additional years because there is no guarantee for future funding. Application packages submitted electronically require prior registration through grants.gov and require same information.



SF-424 Application for Federal Assistance

1. Are dates correct and consistent with the other documents in the grant application package?

Start Date, End Date, Date Received by Federal Agency

Same dates on project statement, budget period?

2. Why are dates important on the SF-424?

These are the dates you want to begin and end your projects.

Requested Start Date can’t be prior to date received by WSFR. You can’t

start a project before it is reviewed and approved. Exceptions exists for

pre-award costs that are requested, documented and approved in award. 3. Are the dollar amounts correct and consistent with other documents in the

package?

Compare estimated cost or budget information in project statement or on

separate budget “form.” This should match the amount of funding requested

on SF 424. Grantee may include subsequent funding years not included

on SF 424 (current request) for planning purposes but must clearly show

projects to be funded in current request. Compliance does not have to be

met for projects not funded in current request – planning purposes.

Revised 3/6/08





SF-424 Application for Federal Assistance (continued)

4. Are Federal and State participation ratios appropriate and legal?

Most WSFR grant programs are 75/25 ratio except for insular areas = 100%.

SWG implementation grants are 50/50, planning grants are 75/25.

See guidance for specific grant program. 5. Is program income reflected on grant application?

If program income is not shown on the example grant package show

where this would be reflected on the blank SF 424. Mention there are

different methods of using program income. Grant award will provide

approved method. Will discuss more in Award module. 6. Does the application contain the original signature of an authorized

individual?

Application must have an original signature of authorized individual.

States/Grantees designate authorized individual 50 CFR 80.11.

Ask participants how do they know who is authorized to sign? States submit

letter each year designating authorized individual and it is listed in FAIMS.

Authorized (AOR) representative is established in grants.gov by

organization’s E-business point of contact after registering in grants.gov.

Authorized Organization Representative (AOR) is then allowed to submit the

application electronically.

Revised 3/6/08



During Pre-Award phase the Grant Application Package is submitted by the grantee and reviewed by WSFR RO. Communication takes place between the grantee and WSFR Regional Office. Grants are usually approved after all information and documentation is received by the RO for the apportioned grant programs. Since the competitive grants are awarded based on ranking criteria, grants submitted for these programs may not be selected for funding.

Review: Up to this point we’ve reviewed the grant application package including the project statement. After the WSFR Regional Office has approved our grant application the grant is awarded. In the next module we’ll discuss the Award phase of the grants management process.



Learning Points

The Grantee/State is responsible for submitting the correct documentation.

Grants cannot be approved without the submission of the appropriate documents. Documents may vary depending on regional/state and program/project requirements.

Grant application is submitted to the Wildlife and Sport Fish Restoration Program Regional Office for review and approval or selection based on competitive process.

Award: Notice of Grant Award


Revised 03/03/2008 Filename: s:\federalaid\courses\course_modules\award\plc-award.doc Enter Name of Course: Project Leaders Course 2008 Enter Tab Number: 7 Handouts: Example grant award letter Program Income Chart

Revised 3/6/08

Award: Notice of Grant Award Instructor Notes


The next phase of the grants management process is the Award phase. During this phase the grantee receives notification that their grant has been awarded. The award letter contains additional information needed to administer and comply with the terms of the grant. During the Award phase the grant funds are authorized and may be obligated in the payment system. These are important steps that make the funds available for use and to be reimbursed by your agency.




Objectives:

1. Identify and explain the purpose of the grant award and the elements contained in the grant award document.

2. Describe the terms of acceptance, grant provisions and special conditions on the grant award.

3. Discuss the obligation of funds for awarded grants.

4. Recognize importance of complying with the terms and conditions stated on the grant award document.

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Once the RO approves the grant an official notification is sent to the Coordinator/Agency Director (maybe to the Accountant too). The notification is a transmittal memo. All regions use a variation of this memo but it must contain certain required elements. Most ROs also return a copy of the AFA-SF-424 document.

The memo serves to notify the grantee that the application has been approved and the grant has been awarded. It sets the award dates, terms and conditions of the award as well as any special conditions or provisions. This was previously accomplished with grant agreement form that you may still see referenced in many documents in the Toolkit. Once the award letter is received by the grantee it should be reviewed and the information or notification disseminated to everyone involved in the grants management process. It is important to review the information contained in the transmittal / award notification because grantees must comply with all provision, conditions, terms and conditions listed. Once notified of the award, acceptance of the terms is accomplished by beginning work, requesting reimbursement of funds or notifying the grantor of acceptance (may be done electronically in the future). Discuss briefly elements contained on letter: Federal ID # - grant award number Dates – performance period, effective dates, grant period Federal share – awarded amount – may not all be obligated, may have a conditional statement, may also list state share (matching). Terms of Acceptance – DOI standard terms, references from 43 CFR 12 and others. Special Provision/Conditions – apply to this particular grant, pay close attention. Signature – authorized federal personnel, usually regional WSFR Chief



Notice of Grant Award

After the grant application package is approved by Wildlife and Sport Fish Restoration Program the grant is awarded. Grantees are sent a transmittal memo containing approved grant information, terms of acceptance and special conditions. Grantees must review the elements contained in the transmittal memo for acceptance and compliance with all grant terms, conditions and any special provisions that may be placed on award.

• Federal Identifier and/or amendment number

• Dates

• Federal Share Authorized

• Terms of Acceptance

• Special Provisions/Conditions

• Signature of Authorized Federal Personnel

Revised 3/6/08



Have participants’ complete exercise on grant award using sample award letter. Be sure participants find 522 FW Chapters for exercise. Debrief:

Grant award dates are important for many reasons. The dates establish the time frame for reimbursement of eligible expenditures A common audit finding is out of period costs. This can often be corrected through coordination and communication within the grantee agency. There are also other issues relating to the award period, income received, reporting requirements and record keeping.



Exercise: Notice of Grant Award

Use the example Notice of Grant Award and Service Manual Part 522 Chapters 16, 17, 19, 23, 25 to answer the following questions. 1. What is the “Effective Date” of a grant award?

Effective date as defined in 25.5 is the starting date of the grant period.

2. How is the “Effective Date” established?

At the time the grant is approved an effective date is established. When the

application is approved prior to requested start date, the effective date

is the date requested. If the application is received after the requested start

date the effective date is either the start date requested or the date the

complete grant package was received by the RO, whichever is later.

The date is included in the Award Notification as either Start/Begin date or

specifically identified as Effective Date. 3. During what period are expenditures eligible for reimbursement?

The begin/end date of the grant award. May be referenced as performance

period or grant period on Award Letter. Exception is pre-award costs that

are approved in Award or contracts approved during award period.

4. What happens if the grantee begins work prior to approval of the grant

application?

Grantees may begin work whenever they choose. If grant is not approved

grantee is responsible for costs incurred. If grant effective date is later than

start date requested, prior costs are not eligible for reimbursement.

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Exercise: Notice of Grant Award (continued)

5. What are ways to prevent costs from being incurred outside of the approved

award period?

Submit “complete” applications prior to requested start date, document &

request pre-award costs if applicable, see 522 FW 16.5. If pre-award costs

are approved it will be listed on award as special terms/conditions.

Coordinate and communicate with your accounting and field staff concerning

approved dates, work and invoices. Monitor dates on the award notification.

Submit amendments if appropriate. 6. What are the requirements regarding budget changes for approved grants?

(Transfers between cost categories or jobs?)

FW 522 Chapter 23 – refer to the 10% rule. CFR requires non-construction

grants to obtain prior written approval (amendment) from WSFR for

cumulative transfers among cost categories/jobs/activities that exceed10%

of the total grant budget. If 10% rule is not waived, the grantee is limited to

re-budgeting 10% of total grant award for any grants where the federal share

exceeds $100,000. WSFR may waive this requirement and allow grantees

to transfer funds between categories or jobs. However, transfers between

subprograms must be approved with an amendment to the grant.

Construction grants always require approval to rebudget funds. 7. What are the methods of using program income?

FW 522 Chapter 19 – deductive, additive, cost sharing. Explain that

participants should be aware when receiving income from activities directly

supported by grant activities. Need to track and account for income and use

in accordance with approved method in award or defaults to deductive.

For BGM may want to share program income chart and discuss more detail.

Revised 3/6/08





Exercise: Notice of Grant Award (continued)

8. Explain the following conditional statement that may be placed on the

Notification of Award: Cost accounting required at the project level.

FW 522 Chapter 17 – Grantee must establish cost codes at project level.

This is the level at which substantiality in character & design were made and

must be tracked. Matching is required at the subaccount, subprogram level. 9. What does it mean if the Notification of Award states: The U.S. Fish and

Wildlife Service approves this grant subject to the availability of funds.

Applies to WR/SFR and associated programs. Because these programs

are permanent & indefinite appropriations (not dependent on Congress),

States receive an apportionment every year. If funds are not available

when the grant is approved, a statement will be included on the Notification

of Award stating that the grant is approved but funds will not be available

until the apportionment is received. States manage obligations of their

apportionments based on State needs.

Revised 3/6/08



Some of these conditions/statements may be

included on the example Notification of Award. There may also be some additional provisions/conditions not discussed. Hold discussion on importance of reviewing provisions/conditions, disseminating information to personnel involved in managing grants and complying with the terms. As you can see the notice of grant award is a very important document that must be reviewed for compliance issues. There are many people that need to be aware of the information contained in the award memo. State WSFR Coordinators serve as central point of contact to coordinate and disseminate the grant award information.



Learning Points

The transmittal memo is the awarding document, states the terms and conditions of the grant; obligates the Federal share of estimated project costs by program (if available); and provides information to monitor uses of funds by subprogram or purpose.

Only costs incurred during the funding period are eligible for reimbursement.

Conditional statements clarify the terms and conditions of the grant agreement.

Post Award: Implementing, Managing and Monitoring the Grant Award


Revised 03/06/2008 Filename: s:\federalaid\courses\course_modules\postaward\plc-post-award.doc Enter Name of Course: Project Leaders Course 2008 Enter Tab Number: 8 Handouts: Example grant package Notes: This module is the same as the BGM module with the following exceptions that are not included in the PLC: Exercise on Requesting Amendments to Grants

Revised 3/6/08

Post Award: Implementing, Managing and Monitoring the Grant Award Instructor Notes


Review objectives for topic. After the grant is approved or the Notification of Grant Award is received the Post-Award phase begins. The Post-Award phase contains many activities that are taking place to perform the grant work, monitor, manage and possibly amend the grant. In this module we’ll look at the activities taking place, what needs to be monitored and how to make changes to the grant if needed. We’ll also discuss the communication that takes place. Communicating and cooperating is especially important during this phase of the grants management process.




Objectives:

1. Identify and explain activities involved in implementing, managing and monitoring grant awards.

2. Describe the communication needed and people involved during grant implementation and management.

3. Explain the importance of monitoring during the grant period and what should be monitored.

4. Describe ways to monitor and evaluate the grant.

5. Determine when a grant needs to be modified and what documentation needs to be provided.

6. Identify reporting requirements.

Revised 3/6/08



What happens once a grant is approved and awarded? What are the next steps? This is when the rubber meets the road. We are ready to start performing the grant work. Let’s take a few minutes and discuss some of the things that are going on when we begin to implement our grant, who is responsible and the type of communication or coordination involved. There’s a list on page X-2 to help us get started thinking about the next steps – implementation. If BGM course discuss general activities, coordination, etc. If PLC have accountant or coordinator help to identify State specific process.



Grant Implementation

Once an Application for Federal Assistance is approved and the Notice of Award is received by the grantee, what are the actions and/or activities that take place and who is involved? Notice of Award

• Review important elements and disseminate information and/or award notice

Establish accounting to manage and monitor grant award

• Accounting/tracking codes for federal funds and matching funds • In-kind • Inventory for real and personal property • Obligation of federal funds • Program income • Financial reporting due dates • Drawdowns (reimbursement of funds)

Establish measures to manage and monitor grant performance

• Work schedules • Purchases • Salaries • Contract services or subgrants • Milestones • Accomplishment reporting due dates • Site visits

Revised 3/6/08



In our next exercise the notice of award has been received, the information disseminated or a copy of the award sent to the financial staff, field staff and others involved. The accounting section has established a code for us to use to charge salaries, supplies, contracts, etc., to the grant. This is the code that we’ll be using to track grant expenditures that are eligible for reimbursement as well as required matching for the grant. Some agencies use a separate code for tracking matching. Our field staff started the work on the ground, they’re charging their time, equipment, supplies or other expenses that were approved and are applicable and allocable to the accounting code that was established for the awarded grant. Let’s take a more detailed look at the activities that are taking place. The questions in the exercise below will prompt us to think about what needs to be done and how we accomplish it. For BGM use the example grant when questions are grant specific.



Exercise: Managing and Monitoring an Approved Grant

Your accounting section has established an internal accounting code to track expenditures for your grant award. Field personnel are performing the work listed in our project statement. Salaries are being paid, supplies purchased and contracts initiated. What happens next? 1. How do you know if funds have been obligated for your grant and who is

responsible for obligating the funds?

Check FAIMS/Smartlink, call RO. Will review FAIMS reports during debrief.

RO does the actual obligation but should be communicating with State to

determine amount of obligation and timing. 2. Who is responsible for monitoring grant expenditures for compliance with

federal rules and regulations?

Combination Coordinator & accountant. Coordinator is aware of projects

listed in project statement and should have knowledge of cost principles.

Accountants have knowledge of cost principles, direct/indirect expenses, etc.

3. How and when do we receive the actual federal funds for grant expenditures?

Explain.

Program is reimbursement. State accountants perform drawdowns using

HHS-Smartlink according to State schedule. Funds electronically deposited

to State’s bank usually next day (requires initial setup). State accountant

is responsible for requesting reimbursement, sometimes this is performed

at the agency level. Monitored using FAIMS, Smartlink, RO fiscal staff.

Revised 3/6/08





Exercise: Managing and Monitoring an Approved Grant (continued)

4. What are the consequences of not receiving grant funds timely and who is

responsible?

Failing to receive funds may cause the State to have cash flow problems.

It can also cause problems with unobligated balances that may be

reverted or could be used on other projects. The State is responsible for

making timely request. Since funds are transferred electronically the next

business day there is typically no delay on the federal side. 5. Are costs incurred prior to the begin date for our example grant allowable?

Pre-award costs must have been documented and requested in grant

application package and must be approved in award. Pre-award costs may

include activities for planning & development, surveys plans, appraisals, etc.

If not specifically approved, costs incurred prior to effective grant date cannot

be charged to grant. 522 FW 1.11B (2), 522 FW 16. 6. Are we required to provide matching funds for our example grant? If so, how

much and when do the funds have to be provided?

Probably unless insular area. Most WSFR grants have a matching

requirement. The matching is usually provided proportionally whether

cash or in-kind. It depends on which part of the CMIA your agency

is required to follow. Most States do not have to match proportionally. 7. Is documentation required when requesting reimbursement for federal funds?

Documentation to support the request for reimbursement (drawdown) must

be on file in the grantee’s office. Auditors verify this information during audits.

In certain high risk grantees the RO may require oversight and require

documentation to be submitted for each request.

Revised 3/6/08






8. A local construction company donates the use of their heavy equipment to

your agency to perform grant related work. Is this an allowable in-kind match? If so, how will the value be determined?

Yes, value of third party contributions applicable to the period to which the

sharing or matching requirements apply. Not necessary to have prior

approval for in-kind. See CFR 12.64 for various methods of valuing

third party contributions. Must document time used and valuation method. 9. Is income received from a grant related activity such as harvesting timber or

fees for services a concern? If so, why?

If it is expected that grant will produce income it should be estimated and

included on grant application. The method in which the income is credited

must also be documented. If not, defaults to deductive method. To use

program income grant would have to be amended. 43 CFR 12.65

The gross income must be deducted from the total outlays prior to

requesting reimbursement and must be reported on the FSR. 10. What tools would you use to help monitor grant/project performance?

Project statement, performance & progress reports, status of contractors, site

visits & field reviews, project planning/tracking system, communication with

field staff, project leaders, managers, coordinator, and fiscal staff.

Ask how WSFR monitors? Performance reports submitted to RO.

We will discuss performance reporting requirements later in module. 11. Could there be compliance issues to address during this phase of the grants

management process?

Yes, if something is uncovered compliance may need to be re-addressed.

Civil rights, ADA, etc.

Revised 3/6/08



Managing and monitoring a grant involves

many people and tools. It is important to monitor progress and pay attention to fiscal, program and compliance concerns.




12. What happens if grant objectives are not met? Are there valid reasons

objectives may not be met?

It depends on the reason the objectives were not met. May have to pay back

funds. There are valid reasons for not meeting objectives, weather delays,

change in key personnel, contractor performance, lack of communication &

coordination. 13. How would you determine if funds are being expended properly and what

tools would be used?

Depends on your role., WSFR Coordinator review financial reports,

employee activity reports, discussions with project leaders, field reviews.

WSFR Regional office review drawdowns, conduct field reviews, discussions

with State coordinator, review performance reports, financial reports.

Also, information might be revealed through audits.

This is and should be a part of the ongoing process. 14. What are some causes of misspent funds?

Poor communication & coordination with fiscal staff, project leaders, and

coordinators. Not monitoring grant dates, allowable expenses, ineligible

expenses, no matching documentation, incorrect valuation or documentation

for in-kind, incorrect use of indirect cost rate or not having approved rate.

You should modify the grant before it ends or credit funds. 15. Does a grant award ever need to be amended or revised?

Yes, to add, delete or modify a project, funding changes, etc.

Changes as a result of monitoring/managing, being proactive.

Revised 3/6/08



As a result of monitoring and managing your grant you see that it might be necessary to make changes to your grant. It is better to take a proactive approach and modify your grant if needed. We mentioned a few reasons why a grant might need to be modified: • Addition, deletion or modification of

project objective or job; • Change in key personnel • Extension of funding period • Increase/decrease federal funds • Revise rate of federal participation How is this done? To modify a grant you submit the SF 424 form. See block 8 on SF-424 Continuation or Revision – have participants review form. Check the revision box and insert letter depending on change, attach a revised project statement or budget attachment with explanation of changes. Also, compliance may need to be addressed depending on changes requested. The amendment / revision must be sent in prior to the ending date of the grant. Send it in early. If you’re changing objectives – make sure the revised objectives still fit within the “need” stated in the project statement.



Modifying Grants

If changes are anticipated during the post award phase a grant revision is appropriate. When to revise the grant:

• Addition, deletion, modification of a project objective or job

• Change in key personnel

• Extension of funding period

• Increasing or decreasing Federal funds

• Revising rate of Federal participation Note: When revising a grant for an addition or modification of a project or job, compliance may need to be addressed.

Modifying Grants

Grant Awards 522 FW 1.5, 522 FW 1.8

Revised 3/6/08



If the original grant application is still valid and has not expired, you can submit a new grant application for the next funding period, Continuation. If not, a New SF-424 would be submitted. All supporting documents must be submitted with the SF-424. If grant is continued, numbering in FAIMS will continue in sequence. If New, new grant numbers will be assigned.



Keeping the Work Going

Prior to the ending date of the grant award, an application may be submitted to continue the project (s) into the next funding period by submitting an SF-424 and supporting documents. “Continuation” is checked as the Type of Application on the SF-424. In addition SF-424 may be submitted for new projects.

Notes:

Revised 3/6/08



Another part of managing your grant is submission of financial and performance reports. Using the references listed summarize the information you find on reporting requirements. We just want a brief description about when the reports are due, the forms or formats to use, etc. We’re going to look at the information to be included in the actual report next. Debrief: Use slides to summarize requirements Reporting Guidelines (5/2/03) were rescinded 2/2/07 (letter to States, Commonweaths & Territories). It was superseded by DOI Policy on FSR (amended May 2004) and Service Manual Chapter 522 FW 17. We also have Interim Guidance for FSR and Performance Reports. Grantees prepare & submit reports, WSFR processes reports and inputs data in FAIMS. Emphasize that failure to submit timely and accurate reports can cause problems. We’ll discuss the consequences of not submitting reports or not submitting them timely next.



Exercise: Reporting Requirements

Review the following references in the Toolkit. Summarize the reporting requirements for financial and performance reports. Service Manual Chapters: Federal Regulations (CFR/FAR): 522 FW 1.12, 1.22 and 1.23 43 CFR 12.80 and 12.81 522 FW 17 Interim Guidance Interim Guidance for Financial Status &

Performance Reporting Financial Reporting:

Use SF-269 long or short form, long form must be used if PI or In-kind.

Required at least annually for grants longer than one year and final at end of

grant period. Due 90 calendar days after anniversary and/or ending date of

grant. May request extension by letter, fax, email prior to original due date,

give revised due date and justification. WSFR may grant one 90 day extension

and provides in writing along with sanctions that may be imposed for non-

compliance. Include SI in block 12 on both interim and final. Federal

investments in nonfederal physical property, boat ramp, land, mooring, etc. Performance Reporting:

No standard format or form but must include specific information – will look at

in more detail in a few minutes.

Report does not have to include financial information but it is needed for

FAIMS. Due dates and request for extensions are same as FSR.

Difference when reporting interim, only activity that has occurred during

reporting period. FSR includes both reporting period and year to date.

Revised 3/6/08



If reports are not received by either the original due date, approved extension date, or an acceptable explanation received (disaster, emergency) WSFR must: (1) Notify the grantee in a letter accompanied by a fax and/or e-mail within 30 days that the due date has passed and that WSFR has not received the required Financial Status and/or Performance Report. (2) Inform the grantee that failure to submit reports by the required due dates renders it not in compliance and may result in the imposition of sanctions including:(a) Withholding cash payments pending receipt of the required report(s) [not required on a notification for an overdue final report]; (b) Denying the use of Federal funds and credit for the use of matching cash and in-kind contributions for all or part of the cost of the activity or action not in compliance [not required on a notification for an overdue final report]; (c) Whole or partial suspension or termination of the current award for the grantee's or subgrantee's program [not required on a notification for an overdue final report]; (d) Withholding of further awards for the program until the required report(s) are received; or (e) Other legal remedies. (3) Request immediate receipt of the report(s) from the grantee. (4) Negotiate a proposed extension date (in cases where WSFR has already granted an extension, this will be an additional extension) not to exceed 30 calendar days. The additional extension must start on the date that WSFR notifies the grantee in writing that a report is late. WSFR must approve the proposed extension date and notify the grantee in a letter accompanied by a fax, and/or e-mail that an approved extension has been granted. The notification must also reiterate the warning and possible sanctions in (2) above. Don’t wait for a notification. Use the FAIMS Report by Period (gives 0-31 days, 32-60 days), Tickler Report & Overdue Report Tickler to monitor. Call RO for status on reports.



Remedies for Non-Compliance

• Report is not received by due date:

o Notify recipient due date has passed

o Inform recipient of non-compliance and sanctions that may be imposed

o Request immediate receipt of report

o May negotiate a 30 day extension date (extension must be issued

in writing )

• Report or explanation is not received after 30 day extension date:

o Issue written warning notice stating non-compliance with grant terms

o Require report to be submitted within 10 calendar days or no further

payments will be made and award suspended

• Report or explanation is not received by end of 10 day period:

o Grant award and payments suspended

o Require report to be submitted within 30 calendar days of suspension or suspension will be converted to termination and withhold further awards

Revised 3/6/08



Now that we know when the reports are due, how to request an extension and the consequences for noncompliance, we’ll take a closer look at the information needed in performance reports. We won’t go over the financial reports in the PLC. The information in project statements, the work described and the performance reports must “connect”. Remember you are reporting on the objectives written in the project statement.

Performance reports should contain the following information: Non-construction & construction Actual accomplishments vs. planned objectives for the period Reasons for slippage, if objectives were not met Additional pertinent information – analysis and explanation of cost overruns or high unit costs, photos, brochures, other information required for specific grant program or type. See Service Manual Chapters 3-15. Remember from earlier discussions on information to include in the project statement and additional compliance requirements these chapters contain specific guidance about reporting for a specific project type, land acquisition, research, etc. Examples: Land Acquisition (6) - Summary of Land Costs and Title Vesting Evidence Research (11) - Final scientific report, professional paper or thesis that draws conclusions about the research. Survey & Inventory (12) - Evaluation of the need to continue the survey and inventory work. Speak to the Adequacy, Need Reliability and Efficiency of continued data collection. Population Management (8) - Report on the species, numbers and locations of stocking efforts. LIP evaluated based on previous grants – ranking criteria 10 points. Others? Report any significant developments (interim reports): Inform WSFR as soon as conditions are known. Problems, delays, adverse conditions that will materially impact objectives Favorable developments – sooner time schedules, lower costs, more benefits Regional Offices must use the performance reports to report on WSFR’s GPRA goals (18 broad goals). This is accomplished by assigning one of the 41 FAIMS activity codes.



Performance Reports

There is no standard report format, but specific information is required. Information in project statements and performance reports must “connect”.

• Performance Reports will contain, for each grant award, brief information on the following: (43 CFR Part 12.80 (b) (2))

o A comparison of actual accomplishments to the objectives

established for the period.

o The reason for slippage, if established objectives were not met. Reasons objectives might not be met

• Weather • Permits • Contractors • Budget • Changes in Key Personnel

o Additional pertinent information including, when appropriate,

analysis and explanation of cost overruns or high unit costs. Photos Brochures Supporting Information

• Additional information relating to the type of project (Service Manual

Chapters 522 FW 3 through 15).

Performance Reports

522 FW 1.22 Monitoring & Reporting Performance

522 FW 17.7 Cost Accounting and Financial Reporting

522 FW 3 through 15 Chapters on Project Types

43 CFR 12.80 Monitoring & Reporting Performance

Revised 3/6/08



Communication and responsibility is shared between field personnel, project leaders, accountants, and federal staff, to ensure projects are successfully completed and compliance requirements are met. Review learning objectives.



Learning Points

Effective communication is essential to successfully implementing a Grant grant.

Grants require managing and monitoring fiscal, program and compliance concerns throughout process.

Anticipated changes as a result of managing and monitoring grant awards may require modifying or amending the grant.

Financial and Performance reports are due 90 days after the grant period or annually depending on award period.

There are negative consequences for not complying with reporting requirements.

Grant Closure


Revised 03/04/2008 Filename: s:\federalaid\courses\course_modules\grantclosure\plc-grant-closure.doc Enter Name of Course: Project Leaders Course 2008 Enter Tab Number: 9

Revised 3/6/08

Grant Closure Instructor Notes


Review objectives for topic.

Grant Closure


Grant Closure

Objectives:

1. Describe the actions and documentation that initiate grant closure.

2. Become familiar with the dissemination of information.

3. Describe the communication and people involved in grant closure.

4. Understand your role in closing a grant.

Revised 3/6/08



One of the things being monitored is the end date of the grant award. As we discussed previously reporting is based on grant award dates. When a grant award comes to an end, reports, performance & financial are due 90 days after the ending date. Submitting the final financial status report initiates the grant closure phase of the cycle. Prior to the end date grantees should be sure all expenditures are charged against project, work is completed, field personnel are aware of grant closing (no more charges) and drawdowns are completed. Once the Regional Office receives the financial status report the process of actually closing the grant financially begins.

Make sure participants understand the difference in submitting reports to close grants versus annual reporting. Point out that the FAIMS information can be obtained on the internet and emphasize the URL of the FAIMS web page: http://faims.fws.gov Access to FAIMS data on the Internet we call iFAIMS. It is available to anyone who has an Internet connection.

Grant Closure


Grant Closure Process

The Grantee/State must submit a: 1. Final Drawdown (request for reimbursement) 2. Performance Report (a final report if closing out a research grant) 3. Financial Status Report (SF-269) A final drawdown should be made through Smartlink to request reimbursement for federal share of grant expenditures. The performance and financial reports are due to the Regional Wildlife and Sport Fish Restoration Program Office within 90 days after the grant’s ending date. If these reports cannot be provided within the 90 day period, a written request for an extension must be submitted prior to the deadline. The Regional Wildlife and Sport Fish Restoration Program Office is responsible for: 1. Monitoring State accomplishments (performance reports, site visits, etc.) 2. Processing the Financial Status Report (SF-269) 3. Updating FAIMS Federal staff reviews and accepts the closure documentation. Information is entered into the Federal Assistance Information Management System (FAIMS.)

Closure and Disposition of Remaining Funds

Submission and acceptance of the final Financial Status Report (SF-269) closes the grant award and denotes disposition of the remaining balance on the award (unused balance of grant funds). The grant award is closed financially. The unused balance may be returned to the grantee, reverted back to the program or used for other purposes depending on the established rules and regulations for each specific grant program.

Revised 3/6/08



Mention FWS Reference Service. Info still being collected.

Point out that the FAIMS information can be obtained on the internet and emphasize the URL of the FAIMS web page: http://faims.fws.gov Access to FAIMS data on the Internet we call iFAIMS. It is available to anyone who has an interent connection. This is an example of the type of information that can be gleaned from the report data used to meet public information requests and to track your grant information. Discuss how future electronic reporting (FAIMS on the Internet) and the flow of information will be important in disseminating information and meeting accountability standards

Grant Closure


Distribution of Information

One of the last things to happen is the distribution of information about the project results. Both Federal and State agencies distribute information through: • Fishing, hunting, boating, and outdoor shows • Journals and magazines • Technical assistance with other states • Accomplishment Reports • Internet (iFAIMS)

Federal Assistance Information Management System (iFAIMS)

The iFAIMS website is located at: http://faims.fws.gov Guest access for general report information is available to anyone with Internet access. (No username login or password is required for this level of access.) Secure access is available for grantees that need to access grant specific information, special report formats, grant status information, detailed fiscal information, etc. (Secure access requires logging in with an assigned username and password. Grantee agencies designate who will receive secure access.)

Revised 3/6/08



Summarize the discussion and emphasize the following learning points. 1) Performance reports are required. 2) State’s responsibility to make final draw. 3) State needs to submit SF-269, Financial Status Report only after # 2 above is done. 4) SF-269 is required within 90 days after the expiration date of the grant. 5) An extension of the 90-day period must be in writing. 6) Disposition of funds – check reports 7) Dissemination of information – available for stakeholders, etc.

Grant Closure


REVIEW Steps in the Grants Management Process

1. Needs Assessment - identifies needs, issues and problems. 2. Identify a Project that would meet the need(s) identified in the needs

assessment. 3. Identify the grant program and grant type appropriate for the project. 4. Prepare and submit a Grant Application package: SF-424, Standard

Assurances, Project Statement, and other required documents. 5. Grant application package is reviewed, approved and awarded. 6. Implementation, Monitoring and Evaluation of the grant. 7. Grant changes and continued implementation, monitoring and evaluation. 8. Grant closure. 9. Dissemination of information. 10. Re-assess needs for new grant and monitor for post closure issues.

Revised 3/6/08



Grant Closure


Learning Points

The grant closure process requires effective communication among several people.

Grantee initiates grant closure by submitting final financial and performance reports.

Submission and acceptance of final financial report closes grant award and disposes of unused grant funds.

Information from performance reports is distributed in various formats to program stakeholders.

The primary role of a project leader in closing a grant is the completion of the performance report and ensuring all charges to the grant are submitted.

Post Closure: Ongoing Responsibilities


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Revised 3/6/08

Post Closure: Ongoing Responsibilities Instructor Notes


Review objectives for topic.




Objectives:

1. Identify responsibilities that continue after grant closure.

2. Discuss A-133 and Program Audits.

3. Describe importance of understanding and applying grant program requirements and guidance.

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The facilities, land and equipment must be maintained according to the grant program rules and regulations. The federal strings attached don’t disappear when the grant award end date is reached or the final reports are submitted. Past performance on grants may affect future funding. Congress and stakeholders want to see progress on the ground before committing additional funds. FWS will be putting useful life into grant award – may go back to make determination on past grants.

In addition to these issues grantees may have contracted or subgranted funds to marinas, local governments, etc., for boat ramps, pumpout stations, mooring and boat docks. There is probably an agreement or contract in place that will need to be monitored beyond the grant date. There’s also audit of subgrantees that may need to be monitored. Examples of sub-grantees: LIP,SWG,CVA,BIG, Boating Access

Shooting Ranges Boating Access



Post Grant Closure Responsibilities

Land purchased with WSFR funds or license revenue.

Land purchased with federal funds carries a perpetual federal nexus which

applies to all land use, ownership, control and disposition. Income issues

with bartering, timbering and mineral extraction. Land purchased with

license revenue must stay within the control of the F&W agency because

of the license fee requirement in WR & SFR Acts. 50 CFR 80.14 (b)

80.18 (c) and 43 CFR 12.71 (b &c), 522 FW 20, 21, 22, 19. Facilities purchased, constructed, or improved with WSFR funds.

Have ongoing responsibilities such as useful life, access and program

income. FWS will be putting useful life in grant award and may go back

to make determination on past grants. 522 FW 10, FW 7

522 FW 21, 22, 43 CFR 80.14 Equipment acquired using WSFR funds.

Must be used by the grantee or subgrantee in the project for which it was

acquired as long as needed whether activity

continues to be funded by WSFR.

When no longer needed may be used for activity currently or previously

supported by federal agency. 43 CFR 12.72 (b). High dollar equipment

purchased on a 1 year grant may have conditional statement on award. Monitoring Cooperative Agreements and Sub-grantees

Binding contracts that have (or should have) protection and performance

requirements that often extend beyond the grant ending date.

public access and hunter education program use of shooting ranges,

disposition/use of user fees. Access, maintenance and useful life.

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Single Audit Act Requirements OMB A-133

The Single Audit Act requires States, Local, and Tribal governments, nonprofit organizations, colleges, universities and hospitals that expend $500,000 or more in Federal grant funds to obtain an annual audit in accordance with the Single Audit Act Amendments of 1996, OMB Circular A-133. Entities expending less than $500,000 in a year, non U.S. based and for-profit grantees are exempt from the Single Audit Act but must make records available for review or audit by Federal agencies or pass-through entities. Because these audits rarely reached WSFR programs the 2000 improvement Act mandated program audits.



Post Grant Closure Responsibilities (continued)

Record Retention

Grantees must retain grant records according to 43 CFR 12.82 and other

program specific regulations. Records are used for audits and reviews to

verify financial transactions to determine if funds are used in accordance

with laws & regulations. Provide objective appraisals of financial accounting

systems and administrative controls. Determines reliability of financial

records and reports. Generally must be kept for 3 years unless audit

finding. Single Audits and Program Audits

The single audit is intended to meet the needs of both the non-Federal

entity and the Federal awarding agency. Additional audits by the Federal

government build upon the work performed in the Single Audit

Only Federal programs determined to be major Federal programs are.

reviewed or tested.

Program audits mandated in 2000 Improvement Act.

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Wildlife and Sport Fish Restoration Program Audits

As specified in the Wildlife and Sport Fish Restoration Program audits Improvement Act of 2000, grantees are audited once each 5 year period for the two most recent completed State Fiscal Years. The Wildlife and Sport Fish Restoration Program audits supplement the Single Audit Act audits. Currently the audits only cover the Sport Fish (SFR) and Wildlife Restoration (WR) programs, but there are plans to begin auditing the State Wildlife Grant Program (SWG) and the Landowner Incentive Program (LIP). Wildlife and Sport Fish Restoration Program has contracted with the Department of Interior, Office of Inspector General to perform the program audits. The audit encompasses assent legislation, license certifications, the income and expenses associated with license revenues, grant expenditures and program income for the most recent two-year period. In addition, the audit includes a review of historical records for the acquisition, condition, use, management, and disposal of real and personal property purchased with either license fees or federal grant funds. Audit findings must be addressed in the corrective action plan (CAP).


417 FW 1 through 6


Congressional Acts

Wildlife Restoration Act Sport Fish Restoration Act

General Guidance > Audit Guidelines

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Review and cover learning points.

Address any Questions / Parking Lot Issues More information on Grants Management – Advanced Course, Project Leaders Courses, more to come. Post –Course Survey (10 Minutes) Ask participants to complete survey online or paper version. Reminder: Toolkit on web, anyone needing Toolkit CDs? Course Certificates



Learning Points

Compliance issues continue, even after the grant is closed.

The Improvement Act of 2000 required additional audits of SFR and WR programs once during a 5 year period.

Taking the appropriate actions improve the audit experience for all parties.

Generally records must be maintained for 3 years from the date of submission of the last expenditure report unless actions involving audits, litigation, claims or negotiations. Records for real property and equipment must be retained until final disposition.

Grantees are accountable for all federal funds received including funds passed through or sub awarded. Grantees should have monitoring techniques in place for subrecipients.



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Land and Facilities 1. Under what conditions may land, purchased with federal monies be sold,

traded or its purpose changed? What about license revenues?

When the State believes that the land can no longer serve the purpose for

which it was purchased. Must have prior approval of the Regional Director.

See 522 FW 6.7( C), 43 CFR 12.71 (b) and (c), 522 FW 20,

50 CFR 80.14 (b), 50 CFR 80.18 (c).

Lands purchased with license revenue must remain in control of the

State Fish & Wildlife agency or revenue returned to agency or diversion

occurs. 522 FW 20. 2. What activities, recreational or commercial are allowed on land and/or

facilities acquired, developed or managed with federal monies?

Must not interfere with the purpose of the land or facility.

522 FW 21 and 22. It is up to the State Fish and Wildlife agency to

decide on allowable activities.

3. How long is the State required to maintain facilities purchased, constructed,

or improved with federal funds and what are the requirements?

For the useful life of the facility, State must have control over the facility,

control may be exercised by lease, contract, etc., must be used for intended

purpose, income generated must be addressed, may be specific to grant

program providing funding, CVA, BIG, Hunter Education.

522 FW 10, 522 FW 7.3



Land and Facilities (continued) 4. What are the concerns when revenue is generated by activities supported by

grant funds or on lands acquired with grant funds? License revenues?

Activities supported by grant funds (open grant) is considered program

income and must be used in accordance with 43 CFR 12.65. Activity is

listed in grant document. Income generated from land purchased with

federal funds (open grant) program income, (closed grant) treated as

license revenue. 522 FW 19. Also, special conditions per grant program.

Other activities by State Fish & Wildlife agency supported by license

revenue must be used by F & W agency. 5. You have been approached by a local farmer for permission to plant and

harvest soybeans on a State Wildlife Management Area that is being operated and maintained using federal funds. In return the farmer has agreed to leave part of the soybeans as a food plot for wildlife. Planting food plots is one of the management activities you have planned for this area. Is this acceptable?

This is an acceptable activity but it must be documented. It is considered

a non-cash transaction, bartering. The agency is required to have formal

legal documentation for this transaction as well as written procedures.

The transaction must be documented as an expenditure and program

income.



Equipment 1. Equipment purchased on a Federal Assistance grant is occasionally loaned to

the State Parks Section for use on a State Park. May this be done under Federal guidelines? Under what circumstances, may the equipment be used outside the project?

No the equipment must be used on the project for which it was acquired.

The equipment may be used on other FA projects as long as it does not

interfere with the accomplishment of the project for which it was

acquired. (522 FW 1.16 B)

2. If the equipment in the question 1 was purchased with license revenue, does

it raise any concerns?

Yes. The use of this equipment without compensation may

represent a diversion of license funds. States should have an inventory

to account for equipment purchases, use and disposal with license fees. 3. What are the requirements for using, managing and disposing of equipment

purchased with federal funds?

States use, manage and dispose of equipment according to State rules

and regulations. 43 CFR 12.72 (b). Should have an inventory and records

until disposal of equipment. High dollar equipment purchased on a grant

may have a conditional statement placed on award with further requirements.



Contracts and Cooperative Agreements with Subgrantees 1. The State Fish and Wildlife agency passed grant funds through to a private

marina for construction of tie up facilities. The construction was completed and accepted. Are there requirements that exist for the agency after the grant is closed? Explain.

Yes. Any time funds are passed through to a subgrantee/subrecipient,

the contract should have protection and performance requirements that

extend beyond the grant award date, throughout the useful life of the

project or facility. In this specific instance there are requirements of the BIG

program that the facility have a useful life of 20 years, be available to the

public and limits on fees charged. 50 CFR 86.30 & 86.31.

There are monitoring issues, audit issues, access, maintenance, useful

life, user fees, etc. These may involve hunter education facilities,

shooting ranges, boat ramps, pump-out facilities, boating infrastructure.

Check specific grant program regulations. 2. List some of the techniques used in monitoring subgrantees.

Document reviews, site visits, performance reports, communication,

information detailed in contract, audits.

43 CFR 12.77, OMB Circular A-133 Section 210 & 400

OMB Circular A-133 Compliance Supplement Part 6 (M)



Meeting Extended or Delayed Grant Program Conditions 1. What was an eligibility requirement of the Wildlife Conservation and

Restoration Program (WCRP)?

The State F&W agencies received the grant funds and agreed to comply

with the statute to develop and implement a Wildlife Conservation Strategy

within five years. The SWG program was implemented and the plan

created for that program meets the requirement of the WCRP.

SWG program also had this same requirement for planning and

approval of plans. 2. What is a requirement of the Wildlife Restoration and Sport Fish Restoration

Programs that should be monitored as State laws and regulations are implemented or changed?

The requirement of protection of license fees for the administration of the

State Fish & Wildlife agency. As State Legislatures enact new laws the

legislation must be monitored for potential impact on this requirement.

Record Retention 1. What requirements must grantees/States follow regarding record keeping for

grant documents/records?

Grantees must retain grant records according to 43 CFR 12.82 and other

program specific regulations. Records are used for audits and reviews to

verify financial transactions to determine if funds are used in accordance

with laws & regulations. Provide objective appraisals of financial accounting

systems and administrative controls. Determines reliability of financial

records and reports. Generally must be kept for 3 years unless audit

finding.

california plc instructor workbook

Documents

course notebook

course leader

course material

precourse work

grant management process

grant closure unit

purpose of training

notice of award unit