 Managing Federal Grants
The HHS Grants Policy Statement (GPS) is the Department of Health and Human Services' new single policy guide for discretionary grants and cooperative agreements. Unlike previous HHS policy documents, the GPS is intended to be shared with and used by grantees. It became effective October 1, 2006 and is applicable to all Operating Divisions (OPDIVS), such as the Administration for Children and Families (ACF), except the National Institutes of Health (NIH). The GPS covers basic grants processes, standard terms and conditions and points of contact as well as important OPDIV-specific requirements. Appendices include a glossary of terms and a list of standard abbreviations for ease of reference.
Overview of Key Grant Actions and Requirements
A brief summary of some of the more common grant actions has been developed by ORR to assist grantees in the management of their grants. Grantees should refer to the full HHS Grants Policy Statement (referenced above) for complete information. Any requests for grant actions requiring prior approval by ORR should be submitted in writing to your Grants Management Specialist with a copy to your Federal Project Officer.
Carryover of Unobligated Balances
Most discretionary grants are incrementally-funded multi-year projects. These projects are generally funded in 12-month increments called budget periods. The funds used to support these projects are annual appropriations intended to be used by grantees in the budget period they are awarded to cover and for the activities approved for that same budget period.
Grantees may request to carry over unobligated balances of funds at the end of a budget period into the next budget period. Requests must be properly justified by the grantee and approved by the Grants Officer with the concurrence of the program office. Unobligated balances of grant funds may only be carried over from one budget period to the one immediately following the budget period from which the unobligated balance originated. A request for a carryover may be submitted at any time during the budget year in which the unobligated balance originated as well as during the subsequent budget year.
In order to be approvable, carryover funds must be used to complete any activities or objectives that were not completed in the prior budget period and for which funds were originally awarded.
To be considered for approval, a request from a grantee to carry over an unobligated balance of funds from the prior budget period must be in writing from an authorized official and at a minimum include:
- A completed SF 269 reporting form for the prior budget year showing the unobligated balance.
- A full description of approved grant activities from the prior budget period that were not completed, an explanation of why established goals were not met, and the grantee’s plan for completing these activities in the current budget period.
- A detailed budget for the unobligated funds and a budget narrative describing how the grantee proposes to use these funds in the current budget period. Unobligated balances of funds cannot be carried forward into the next budget period to perform new work.
No Cost Extensions
A no-cost extension is a continuation of activities already begun under the grant but not completed as of the end of the project period. The final budget period of a project period may be extended – without additional funds or a change in scope – one time for a period of up to twelve months.
No-cost extensions should be made 45-90 days prior to the end of the project; they MUST be made 10 days prior to the end of the project period.
A request for approval of a no-cost extension must be in writing from an authorized official and include:
- A letter explaining why the extension is necessary and the length of time requested for the extension.
- A completed SF 269 reporting form showing the amount of funds unobligated during the budget period.
- A detailed budget for the unobligated funds and a budget narrative describing how the grantee will use these funds during the extension period.
Grantees must submit the final project report and SF 269 no later than 90 days after the end of the no-cost extension.
Change in Scope of the Project
A change in scope occurs when the grantee proposes to change the objectives, aims, or purposes identified in the approved grant application. In addition, other changes are clear indicators of a change in scope or serve as indicators that a change in scope would be likely. Actions likely to be considered a change in scope include, but are not limited to:
- Transfer of the performance of substantive programmatic work to a third party through a subgrant, consortium agreement, contract, or any other means.
- Significant rebudgeting of a grant. Significant rebudgeting occurs when, under a grant where the Federal share exceeds $100,000, cumulative transfers among direct cost budget categories for the current budget period exceed 25 percent of the total approved budget (inclusive of direct and indirect costs, Federal funds, and required matching or cost sharing). This threshold serves as a quantitative indicator of a possible change in scope.
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The addition of a new line item to a budget.
- Replacement of or changes in the status of the principal investigator (PI) or project director (PD), i.e., if the PI/PD will withdraw from the project entirely, be absent from the project during any continuous period of 3 months or more, or reduce time devoted to the project by 25 percent or more from the level that was approved at the time of the award.
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Replacement of key personnel.
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Change of grantee organization.
Requests for changes to the scope of a project should be made in writing by an authorized official and provide sufficient information for the need for a change in scope. Resumes for new key staff should be submitted to the ORR Federal Project Officer. In the case of significant rebudgeting, a letter of request signed by the authorizing official should be submitted with a justification and side by side budgets indicating the original budget, the line items and amounts to be changed, and the final amounts per line item.
Closeout Procedures
Grantees shall submit, within 90 calendar days after the end of the project period, the final Program Progress Report and final Financial Status Report (SF-269). Both reports should cover the entire project period. These reports are submitted in addition to the semi-annual progress and financial reports for the last six-month period of the project. Please note that funds must be liquidated within 90 calendar days for obligations entered into prior to the end of the project period.
Reports should be submitted to the Grants Management Specialist with a copy to the ORR Federal Project Officer.