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The questions and answers presented here are provided as a resource to our grantees, but are not intended to replace communication with your Department of Education (ED) program officer. Please continue to contact your program officer with specific questions about your grant awards.
Project directors and/or other grant personnel who are new to the grantmaking process should review the Grantmaking at ED publication (http://www2.ed.gov/fund/grant/about/grantmaking/index.html), which is a non-technical summary of ED's discretionary grants process (application, review, award, administration, grant closeout, and audit) and the laws and regulations that govern the process.
In addition, online grants management training and resources for project directors are available at: http://e-grants.ed.gov/training/GMT0101000.htm.
TOPGrantees are allowed a certain degree of flexibility to make post-award changes and budget revisions without prior approval. Section 74 of the Education Department General Administrative Regulations (EDGAR) generally permits grantees to undertake the following administrative actions without seeking approval from their program office. Usually the program office requires the grantee to provide a notification of the change, including supporting justification:
If the change you wish to make is beyond these allowable administrative actions, you must contact ED for prior approval. Grantees are urged to review the sections in EDGAR relating to the type of change they wish to make.
TOPProposed project and/or budget changes must be submitted in writing to your ED Program Officer. The proposal should include the following documents:
Upon receipt of the written request, the program staff may contact grantees directly for clarification or additional information as needed.
All submitted requests for programmatic and/or budget changes are evaluated on a case-by-case basis. The decision to approve or disapprove a request is based on requirements imposed by applicable Federal statutes, including the General Education Provisions Act (GEPA), program legislation and regulations, EDGAR, and OMB circulars. All resulting costs and activities related to approved changes must be allowable. No official may authorize any administrative actions that conflict with any applicable Federal statute, program legislation or regulation, EDGAR, grant conditions; or permit changes that would alter the scope or objectives of a competitive discretionary grant.
TOPSection 74.25(e)(3) of EDGAR states that, "(e) Except for requirements listed in paragraphs (c)(1) and (c)(4) of this section, the Secretary may waive cost-related and administrative prior written approvals required by this part and OMB Circulars A-21 and A-122. These waivers may authorize recipients to do any one or more of the following: (3) Carry forward unobligated balances to subsequent funding years." Based on this regulation, you may carry-over funds however they can only be spent on approved activities listed in your application or other legislatively allowable activities.
TOPThe legislatively allowable activities the PBI programs are listed in the Section 318 of the Higher Education Opportunity Act (HEOA) as amended, as well as OMB Circular A-21. If you are uncertain whether proposed activity is legislatively allowable or not you should always contact your assigned Program Officer to inquire. They will issue a written response with a determination.
TOPYou are urged to read 74.22 of EDGAR to learn more about Federal requirements related to grant payments. For any cash that you draw from your Department of Education grant account, you must:
In order to meet these requirements, you are urged to:
Keep in mind that the Department monitors cash drawdown activity for all grants on a weekly basis. Department staff will contact grantees who appear to have drawn down excessive amounts of cash under one or more grants during the fiscal quarter to discuss the particular situation. Grantees that fail to follow Federal cash management requirements may be designated as high-risk, which may affect future funding.
TOPGrantees that spend $500,000 or more in combined Federal funds (regardless of agency) during fiscal years ending after December 31, 2003, or $300,000 or more in Federal funds during fiscal years ended on December 31, 2003 or earlier, are required to have an annual institutional audit. Generally, these audits, referred to as "A-133 audits" or "single audits," review expenditures of Federal funds across an entire organization instead of specific costs of individual grants. These audits must be conducted in accordance with "Standards for the Audit of Governmental Organizations, Programs, Activities and Functions," published by the Comptroller General of the Government Accountability Office (GAO). Independent Non-Federal auditors selected by the grantee may perform these audits. Grantees that fail to meet the A-133 audit requirement may be designated as high-risk, which may affect future funding.
TOPAccording to the Higher Education Opportunity Act (HEOA) as amended, grant funds used for endowments must be matched in equal or greater amounts with funds from non-Federal sources. In addition, no more than 20 percent of an annual grant award can be used to establish or increase an endowment fund at the institution.
If a grantee institution decides to use any of its grant funds for endowment purposes, it must match those grant funds immediately with non-Federal funds when it places those funds into its endowment fund.
TOPYou must keep records regarding the use of grant funds, compliance with program requirements, and the date the project used to demonstrate the effectiveness of the project in meeting the grant's objectives. Keep your copy of the approved application. The financial records must show the amount and source of all funds spent on the grant, including any matching funds that were promised in the approved application. The records must document how all federal and matching funds were used. You must also keep records that document other types of information you provided the Department in your annual or final reports, such as records of program participants and the source data used to report on performance measures.
If you purchase equipment with grant funds, you must maintain inventory records until the equipment is no longer needed to meet the project objectives, and then you should request disposition instructions from the Department. Keep copies of all correspondence with the Department regarding the project; GEPA (20 U.S.C. 31) and EDGAR regulations (34 CFR 75.730-732) provide specific requirements for record retention. You may need these records to demonstrate to program monitors or auditors that all expenditures and activities you conducted with the grant were allowable and accurately reported.
TOPHelp with G5 is available through e-mail or by calling the G5 hotline.
Hours of Operation: 8:00 a.m. to 6:00 p.m., Monday-Friday, ESTTOP
Toll Free: (888) 336-8930
TTY: (866) 697-2696
Local: (202) 401-6238
E-mail: edcaps.user@ed.gov
The Code of Federal Regulations (CFR) can be accessed at www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR.
Hard copies of the CFR are often available in the reference section of major libraries. For information about purchasing the CFR, go to the GPO online bookstore at http://bookstore.gpo.gov or call the Superintendent of Documents at (202) 512-1800 or toll free at (866) 512-1800.
TOPA PDF version of EDGAR is available for download and printing at http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html.
The most recent regulations that comprise EDGAR can also be found in the Code of Federal Regulations. Please note that EDGAR comprises only Parts 74-99.
TOPElectronic versions of ED Grant Application and other Forms are available at http://www2.ed.gov/fund/grant/apply/appforms/appforms.html.
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Last Modified: 07/06/2011
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