fulfilling epa grant requirements environmental protection agency phillip schindel, associate award...
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Fulfilling EPA Grant Requirements
Environmental Protection Agency
Phillip Schindel, Associate Award OfficialAriadne Goerke, Attorney Advisor, OGC
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Congratulations! It’s A Grant!
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Congratulations! It’s A Grant!
What is the big picture for grant requirements?
What is the framework for grants management?
What are some particular concerns? What do we do about them?
What do YOU want to cover?
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Congratulations! It’s A Grant!
What is it?
It’s a Gift With Strings
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Congratulations! It’s A Grant!
Statute
Regulation
ExecutiveOrder
OMBCircular
TC
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Specific Strings Attached
Statute
Regulation
ExecutiveOrder
OMBCircular
TC
Brownfield Administrative
Cost Prohibition
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Specific Strings Attached
Financial Management Systems
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Specific Strings Attached:Financial Management Systems
AccountingSystem
Procurement Personnel
PropertyTravel
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Slow Progress Missing Reports Use of Funds Outside the Workplan Lack of Adherence to Terms & Conditions Drawdown of Funds either Ahead or Behind
What Is Described in Progress Reports
Post-Award Concerns
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The Case of…The Missing Reports
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Minor Negotiation Changes
Time Money Workplan Modification
Followup Actions
Resolving Post-Award Concerns:Basic Problems
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Performance Issues Misuse of Funds EPA site visit disclosures Audit problems
Resolving Post-Award Concerns:Massive Problems
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The Case of…The Site Visit
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PSA on Audits
Top 10• Late/Untimely reports• Lack of documentation• Inadequate monitoring of
sub-recipients• Inadequate time/effort
reports• Inadequate reports • Co-mingling of funds• Excess cash on hand• Unallowable costs• Inappropriate changes• Conflicts of Interest
Prevention• Understand
Conditions• Check with EPA PO/GS• Get it in writing• “Paperwork” is Proof• Keep accounting
records• Draw funds for
immediate needs only• Communicate early
and often
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High Risk/Reimbursement Withhold Funds Order Work to Cease Until
Deficiencies are Corrected Require Repayment Terminate or Annul Refer to SDD
Resolving Post-Award Concerns:Remedies
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◦ I had to go on a long honeymoon in Italy and couldn’t pay for it myself.
◦ My Project Officer told me to spend it, so I did.
◦ I needed new clothes!
Resolving Post-Award Concerns:Misuse of Funds
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EPA provided grant funds for school bus diesel retrofits
State Grant Manager solicited bids A new company made a proposal to
subcontract to several known and reputable companies
The Case of…The Conflicted Interests
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Buses started breaking down State Grant Manager started avoiding work The couple fled the country
They’re back now.
The Case of…The Conflicted Interests
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High Risk/Reimbursement Withhold Funds Order Work to Cease Until
Deficiencies are Corrected Require Repayment Terminate or Annul Refer to SDD
Resolving Post-Award Concerns:Remedies
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Communicate Don’t be late It’s not free money But it’s still great!
What’s the Moral of This Training?
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Resources
Administrative RequirementsOMB Circular A-89
Catalog of Federal Domestic Assistance
OMB Circular A-102
Grants and Cooperative Agreements With State and Local Governments
OMB Circular A-110, Relocated to 2 CFR, Part 215
Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations
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Resources
Cost Principles
OMB Circular A-21, Relocated to 2 CFR, Part 220
Cost Principles for Educational Institutions
OMB Circular A-87, Relocated to 2 CFR, Part 225
Cost Principles for State, Local, and Indian Tribal Organizations
OMB Circular A-122, Relocated to 2 CFR, Part 230
Cost Principles for Non-Profit Organizations
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Resources
Audit Requirements
OMB Circular A-133
Audits of States, Local Governments, and Non-Profit Organizations
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Questions?
Statute
Regulation
Executive
Order
OMB
Circular
TC
AccountingSystem
Procurement Personnel
PropertyTravel
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If you have any questions, please feel free to contact us at:
[email protected] , (202) 564-5293
[email protected] , (202) 564-5471
Thank You