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

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3. 3  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?

4. 4  What is it? It’s a Gift With Strings

5. 5 Statute Regulation Executive Order OMB Circular TC

6. 6 Statute Regulation Executive Order OMB Circular TC Brownfield Administrative Cost Prohibition

7. 7  Financial Management Systems

8. 8 Accounting System Procurement PersonnelPropertyTravel

9.  Slow Progress  Missing Reports  Use of Funds Outside the Workplan  Lack of Adherence to Terms & Conditions  Drawdown of Funds either Ahead or Behind What Is Described in Progress Reports 9

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11.  Minor Negotiation  Changes  Time  Money  Workplan Modification  Followup Actions 11

12.  Performance Issues  Misuse of Funds  EPA site visit disclosures  Audit problems 12

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14. 14 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

15.  High Risk/Reimbursement  Withhold Funds  Order Work to Cease Until Deficiencies are Corrected  Require Repayment  Terminate or Annul  Refer to SDD 15

16. ◦ I had to go on a long honeymoon in Italy and couldn’t pay for it myself. ◦ My Project Officer told me to spend it, so I did. ◦ I needed new clothes! 16

17.  EPA provided grant funds for school bus diesel retrofits  State Grant Manager solicited bids  A new company made a proposal to subcontract to several known and reputable companies 17

18.  Buses started breaking down  State Grant Manager started avoiding work  The couple fled the country  They’re back now. 18

19.  High Risk/Reimbursement  Withhold Funds  Order Work to Cease Until Deficiencies are Corrected  Require Repayment  Terminate or Annul  Refer to SDD 19

20.  Communicate  Don’t be late  It’s not free money  But it’s still great! 20

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

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

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

24. 24 Statute Regulation Executive Order OMB Circular TC Accounting System ProcurementPersonnelPropertyTravel

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