How to Manage Your Grant

Your Notice of Award (NoA) contains administrative information, legislative and fiscal data, and names and phone numbers of grant and program office staff.

If you receive a multi-year award, we will include information on anticipated subsequent funding periods and their tentative levels of funding.

Review Terms & Conditions

Carefully review all portions of your NoA to understand the terms and conditions of your award and respond to any time-sensitive requests. Failure to respond may result in a negative action.

Your NoA may include both standard and special provisions that we consider necessary to:

• Attain the objectives of the project;
• Facilitate post-award administration;
• Conserve funds; or
• Protect the federal government’s interests.

You are bound by the terms of award, as are we as the awarding agency. If we make modifications—a change in the budget and project period of funding, amount of support, or in the terms and conditions—we will send you a revised NoA.

How do we accept the terms of our award?

You indicate acceptance of the terms of your award when you request funds from the Payment Management System (PMS).

How do we respond to these conditions?

You should respond to these conditions through the Electronic Handbooks (EHBs).

Open up the Grant Handbook associated with the award and select “Monitor Schedules.” This will display the list of upcoming submissions that are pending action.

• You may select and start any of the displayed submissions, upload required documents and, when complete, submit to us.

EHBs Tip: The EHBs generates a submission tracking number at the start of the submission. Be sure you receive an on-screen confirmation message that you successfully submitted your submission. If you do not, the submission has not gone through, and we have not received it.

Once we make an award, we post funds in the Payment Management System (PMS).

To access and make drawdowns on your funds, you first need to establish a PMS account.

The PMS will send you a packet to establish your account, which includes:

• Payee Identification Number (PIN)
• Direct Deposit Sign-Up Form SF-1199A (SF-1199A)
• Recipient Training CD
• Primary Contact Person Form

Complete the SF-1199A and Primary Contact Person forms and return to your PMS representative. Your representative will then provide you a temporary password via certified mail.

Read the PMS User Guide.

How do we request funds to make payments?

You may make grant payments via one of several advance payment methods or by cash request on a reimbursement basis.

If the cash request is for an advance payment, you may request funds monthly based on expected payments during the succeeding month and the amount of federal funds already on hand.

You may submit a request for reimbursement more often, if we authorize you to do so.

How quickly must we make payments if you advance us federal funds?

If we advance you federal funds, you must make payments (checks written, signed, and issued to the payees) by the close of business the next workday you receive the funds.

How should we handle any interest we earn?

You should place federal funds in an interest bearing account. On an annual basis, you must transfer any interest you earn on advances of federal funds under all federal grant awards and sub-awards that, combined, exceeds $250 per year (nongovernmental) or $100 per year (governmental, other than states).

You must maintain a Financial Management System (FMS) to accurately record, report, and manage the funds we provide you.

FMS Requirements:

• Written policies and procedures
• Procedures for determining allowable costs
• Procedures to minimize the time between the transfer of HRSA funds and payment of funds

How should we handle program income?

You must have a written procedure to account for program income. These procedures should provide reasonable assurance that you correctly earn, record, and use program income per program requirements.

At a minimum, you should:

• Set realistic performance targets for the generation of program income
• Analyze variances between expected and actual program income
• Use an information system that identifies program income collections and usage

When do we need to perform a non-federal audit?

If your organization spends over $750,000 in federal funds (all federal funds including HRSA funds) within your organization’s fiscal year, you must have a Single Audit performed by an independent Certified Public Accounting (CPA) firm.

How do we determine allowable costs?

You must have written procedures for determining allowable costs. All parts and sections within 45 CFR 75 apply to educational institutions, state and local governments, and non-profits. The regulation text notes any exceptions by entity type.

What should we include on supporting documentation?

You must maintain adequate documentation to support all costs charged to your award.

At a minimum, you should provide:

• Personnel approving and pre-auditing expenses with a list of allowable and unallowable expenses
• Adequate separation of duties in review and authorization of costs
• Training on allowable and unallowable costs under federal awards to your staff

Is there a period of availability for allowable costs?

If we specify a funding period in your NoA, you may only charge allowable costs resulting from obligations incurred during the budget/project period, and pre-award costs we authorize, to the award.

At a minimum:

• Put a procedure in place to communicate period of availability requirements and expenditure deadlines to individuals responsible for program expenditures, including automated notifications of pending deadlines, if possible
• Review payments by individuals knowledgeable of the period of availability of funds
• Ensure an accounting system is in place that prevents obligations or expenditures outside the period of availability

How do we avoid misspending grant funds?

Follow our tips on Developing Effective Financial Management Practices (PDF - 209 KB).

You must report changes to budget and program plans. If these changes could significantly affect the project or materially impair the ability to meet objectives, we require prior approval.

Can we move funds from one budget category to another?

For post-award changes, you may re-budget within, and between, budget categories in the approved total direct cost budget of the project to meet unanticipated requirements or to accomplish certain programmatic changes.

However, there are certain circumstances, as described in the HHS Grants Policy Statement, for which we require prior approval.

What are the most common actions requiring prior approval?

Key Personnel Changes
If the Principal Investigator (PI)/Project Director (PD) or other key personnel named in the NoA:

• withdraws from the project entirely;
• is absent during any continuous period of three months or more; or
• reduces the time they devote to the project by 25% or more from the level that was approved at the time of award.

Include the following in your Prior Approval Request via the EHBs

• Effective date of the change
• Justification for the change
• Qualifications of the proposed replacement PI/PD
• Curriculum vitae of the proposed replacement PI/PD
• Level of effort this individual will undertake
• Budgetary changes resulting from the proposed change

Budget Revisions
Unless otherwise restricted by the terms of your NoA, you may make post-award programmatic and budget revisions within and between approved budget categories up to 25% without prior approval.

Significant re-budgeting requires prior approval.

Significant re-budgeting occurs when, under a grant with a federal share exceeding $100,000, cumulative transfers among direct cost budget categories for the current budget period exceed 25% of the total approved budget—includes direct and indirect costs, whether chargeable to federal funds or required matching or cost sharing—for that budget period or $250,000, whichever is less.

Include the following in your Prior Approval Request via the EHBs:

• Revised SF-424A or 424 R&R, and possibly the 424C
• Line item budget
• Narrative justification

What if our institution has never negotiated an indirect cost rate?

To receive indirect costs under a federal award, your organization must have a federally-negotiated indirect cost rate agreement. Such an agreement is generally not negotiated until an organization is the direct recipient of an award.

What other actions/revisions require prior approval?

Find a full summary of actions requiring prior approval in Part II of the HHS Grants Policy Statement (PDF - 1 MB).

How do we submit a request for prior approval?

Use the EHB Prior Approval Requests to start your request, upload required documents, and when complete, submit your request. The PO and GMS will then review your prior approval request.

How will we know if you approved our request for prior approval?

An approval is official when we issue you a revised NoA reflecting the approved request.

Is there any way to waive prior approval requirements?

In some cases, we may waive prior approval requirements through "Expanded Authority." Review the "Remarks" section of your NoA to find out if you have these privileges.

What does Expanded Authority cover?

Expanded authority covers carryovers and no-cost extensions (NCEs).

• Carryovers: You may carry over up to 25% of the total award amount of the budget period from which you will transfer the unobligated funds into the consecutive budget period for allowable costs within the original scope of the project.
• No Cost Extensions (NCE): You may perform a one-time, no-cost extension of the budget and project period end dates up to 12 months. If you require a second NCE beyond the initial 12-month Expanded Authority extension, you must follow prior approval no-cost extension procedures, i.e. submit a request through the EHB Prior Approval Request.

You must submit both carryovers and NCEs in the EHB for documentation purposes. In the case of an NCE, this will generate a revised NoA.

How do we request carryover of unspent funds from one budget period to the next?

Include the following in your request:

• An explanation of why the funds remain unspent
• A statement of project activities you plan to accomplish if we approve the carryover
• A detailed budget page
• A budget justification

Generally, we won't approve your request until you submit the appropriate FFR, and it indicates the available funds.

When should we submit carryover requests?

Submit carryover requests as soon as possible, and no later than 30 days, after submission of the FFR to maximize the amount of time in the next budget period in which you may spend funds. Do not spend carryover funds until we give you prior approval.

How do we request a no-cost extension for our award?

Unless provided as an expanded authority, you must obtain prior approval for any extension up to 12 months. We will not approve any extension request if the primary purpose of the proposed extension is to permit the use of unobligated balances of funds.

In the EHB prior approval module, submit the following with your request:

• A statement about why you need the extension
• The duration of the extension (not to exceed 12 months)
• Project objectives you plan to complete during the extension period
• A detailed budget page
• A budget justification for unobligated funds you anticipate will remain at the end of the current budget period

There are three types of property: real property, equipment, and supplies.

What do you consider real property?

Real property is any land, including land improvements or structures, that you purchase with award funds, excluding movable machinery and equipment.

Title to real property remains with you, provided you use the property for the authorized purpose of the project.

Can we use real property for other purposes?

Your use of real property for other federally sponsored projects requires our prior approval. We limit this to projects with purposes consistent with your original HRSA project.

How should we dispose of the real property?

When you no longer need the real property, you must request disposal instructions from your GMS. Depending on individual circumstances, different options for disposal are available. It may include sale of the property, transfer to another service provider, or another method.

What do you consider equipment?

Equipment refers to actual, concrete personal property, including exempt property charged directly to the award. It must be useful for more than one year and an acquisition cost of $5,000 or more per unit.

If you use federal funds to purchase equipment:

• The title of the equipment vests with you
• We always reserve the right to order the transfer of the title of the equipment back to us or a third party that we name (we reimburse you for your share in its value)
• State laws and procedure govern use, management and disposal of equipment acquired by a state under an award
• You must use the equipment for the project as long as needed for the original supported activity, even if award support ends
• You may not use the equipment as collateral

Title to equipment acquired by your sub-recipient vests with the sub-recipient upon acquisition.

The same property management rules apply.

How should we dispose of equipment?

In regards to equipment disposal, we will not issue instructions, nor seek recovery of equipment worth less than $5,000.

If you purchased equipment with a current Fair Market Value of $5,000 or greater, you may continue to use the equipment for the original project. If you no longer need it, you must request disposal instructions from your GMS. You may not donate the equipment.

Is equipment the same as supplies?

No. We define supplies as personal property, excluding equipment and concrete property, with an acquisition cost less than $5,000.

Do we have to report on property we use to carry out the award?

Yes. We require property reports to track the status of the property you used to carry out the award.

You may acquire a variety of commercially available goods or services in connection with a HRSA-supported project or program.

What procurement procedures must we follow?

You can use your own procurement procedures that reflect applicable state and local laws and regulations, as long as those procedures conform to the applicable HHS regulations (45 CFR 75.326 through 335).

Are we responsible for contractual issues?

You are responsible for the settlement and satisfaction of all contractual and administrative issues related to contracts entered into, in support of an award. This includes disputes, claims, protests of award, source evaluation, or other matters of a contractual nature.

How should we handle competitions when procuring with federal funds?

Avoid real or perceived conflicts of interest and non-competitive practices among contractors when procuring with federal funds.

To ensure objective contractor performance and eliminate unfair competitive advantage, you should exclude contractors that develop or draft applications, or contract specifications, requirements, statements of work, invitations for bids, and/or requests for proposals.

You must submit financial reports and progress reports. If we need you to submit more reports, we'll indicate so in your NoA.

You'll submit progress and performance reports into the EHBs. You'll submit the Federal Financial Report (FFR) into the Payment Management System (PMS).

What financial reports must we submit, and when?

You must complete a final financial report to close out your award. You must submit financial reports online. You'll need invoices with purchases prices, quantities, and serial numbers to complete the report.

You can find your report’s due date on your NoA under the Reporting Requirements.

How should we use the Federal Financial Report (FFR)?

Use the FFR to report cash transactions to the PMS on a quarterly basis and to report expenses to us.

When do we submit the Federal Financial Report (FFR)?

• Quarterly: Submit the required FFR/SF-425 to the PMS.
• Annually: Submit the FFR via the PMS every year.

Locate the specific due date of your annual FFR on your NoA or on the FFR status table in the EHBs.

Note: Although you report it annually, it is a cumulative report for all expenditures over the document project period.

When should we submit the final FFR?

We require a final FFR for any grant terminated, transferred to a new recipient, or any award at the end of the project period (or if comprised of multiple competitive segments, at the end of each competitive segment).

How do we submit the FFR?

You’ll need to request PMS access. Then you can submit, review, or approve the FFR in the PMS.

Can anyone access the FFR in the PMS?

Any user can request access to the FFR Module in PMS. However, you should follow your organization’s internal control policies and procedures to figure out who should request access.

Who has access to the FFR in the EHBs?

The Business Official and Authorizing Official. They can view FFR status and get a read-only version of the completed report in the EHBs.

Will you monitor and report program performance on our award?

Yes. Under the Code of Regulations (CFR), program and grant officials must monitor your financial and program performance. You must maintain and make the grant files available for review and inspection for three years. The records include all financial and programmatic records and supporting documents.

What are our record-keeping responsibilities?

You must retain:

• Financial and program records
• Supporting documents
• Statistical records
• All other records that we require in the terms of your award or that we consider relevant to your award

How long must we keep these records?

You must keep these records for a period of three years from the date you submit your final FFR.

If your records are undergoing an audit, litigation, or other action, keep the records until the end of the appropriate retention period, or until the action is completed, whichever is later.

You close out your award after the project period expires—or we terminate it.

This process ensures that we:

• Receive and evaluate all final reports
• Determine allowable costs
• Determine amounts due either to us or to you
• Make payment arrangements

When should we prepare for award closeout?

You should prepare three months prior to the grant’s end date. This is so you can accurately forecast expenses and make entry adjustments.

You must review the initial NoA, program guidance, and any emails our program office sends you with specific closeout instructions.

What additional activities must we complete, and when?

Within 90 days after the end of the project period, or the date indicated under the reporting requirement on your NoA, complete these activities:

• Reconcile financial expenditures by liquidating all obligations incurred for all budget categories
• Complete and submit the final FFR (SF 425) in the PMS
  • It must not include any unliquidated obligations
  • It must account for all funds awarded within the grant document
  • It must reconcile with PMS expense reporting
• Complete and submit your final quarterly report in PMS
• Submit final progress and performance reports to us--via the EHBs--for review and approval
• If you purchased equipment under the grant account, submit a final equipment list
• Return any unspent funds, or those due because of refunds, corrections, or audits to the PMS
• Complete and submit a final audit, if required
• Refer to the HHS Grants Policy Statement (GPS) (PDF - 1 MB), Record Retention and Access (II-89), for additional information

Are there penalties for not returning excess funds?

We may recover funds paid to you in excess of the amount stated in the terms and conditions of the award, including any misspent funds or unallowable costs.

If you do not pay back the funds by the time we specify for repayment, we may collect the debt by:

• Making an administrative offset against payments that would be due under other awards;
• Withholding advance payments that would otherwise be due; or
• Taking any other action permitted by statute.