• What responsibilities do I have under a discretionary grant or cooperative agreement?
• What must I do if I need to change some part of my project from the original application?
• What can I do to help my request for a change get processed quickly?
• Do OMB circulars apply to my grant award?
• How do I make sure that I am complying with the regulations that apply to my award?
• How does the Department know how my project is doing?
• What do I need to do to prepare for a site visit?

Grantees often ask how they know if they’re meeting all of ED’s requirements. In fact, there is more than one answer to that question since a grant project is really a combination of different efforts: performing the substantive activities related to the project’s professional discipline or field of endeavor, managing the personnel and the other administrative aspects of the project, learning and following the various requirements of law and regulation that govern federally funded projects, and undertaking the whole project within the framework of the organization that has received the grant and is sponsoring the project activities. This section presents some of the most frequently asked questions grantees have about their responsibilities in ensuring project success.

What responsibilities do I have under a discretionary grant or cooperative agreement?

You have the following major responsibilities when undertaking a project funded by the Department of Education:

• perform the work promised in the application;
• exercise proper stewardship of federal funds;
• comply with all statutory and regulatory requirements;
• draw down funds as appropriate for obligations made under the grant;
• demonstrate or measure progress toward achievement of project goals;
• report all required information to the Department; and
• maintain records that document the activities and expenditures of the grant.

In addition, each award for a discretionary grant or cooperative agreement imposes specific responsibilities on a grantee, depending on the program from which funding is received.

What must I do if I need to change some part of my project from the original application?

If you need to alter some portion of your project’s activities, the first step is to determine whether or not the planned change requires prior approval. Many changes do NOT require the prior approval of the program office. Part 75 of EDGAR gives grantees guidance regarding various administrative changes to their grants. The provisions generally permit grantees to undertake the following administrative actions without seeking prior approval from their program offices, although, in some cases, a notification with supporting justification might still be required:

• extend the project period one time at the end of the grant for a period of up to 12 months;
• carry funds over from one budget period to the next;
• obligate funds up to 90 days before the start date of the grant's performance period; and
• transfer funds among budget line items.

The Department will not permit a grantee to change the objectives or scope that were originally outlined in the application and scored by reviewers during the application review process. This policy is designed to provide basic fairness to applicants for discretionary grants. Grantees are urged to review the applicable sections in EDGAR relating to the type of change(s) desired. If you are still not certain whether prior approval is necessary after reading the regulations, contact the program staff person shown on your GAN for technical assistance.

It is the goal of the Department to reduce the paperwork burden on grantees, including those related to administrative actions, to the fullest extent possible. However, if prior approval is required, the request should be sent to the program staff person identified on the GAN by e-mail, fax, or regular mail. Grantees can also make changes to their grants through e-Administration, which is accessed from the Department’s e-Grants home page. The e-Administration module allows registered users to request certain changes to their grant awards via ED’s electronic grant system. Users can submit a request and track when the ED program contact reviews it and when a decision or change is made. Once the request is processed, the grantee receives a system-automated e-mail notification specifying whether the request is approved, accepted, or disapproved. For some e-Administration actions that require prior approval, program staff may contact the grantee to obtain further justification or clarification regarding the request. Administrative actions that require prior approval may take up to 30 days to process. Grantees are notified in writing once a determination is made regarding a requested change. Grantees are urged to use electronic communication as much as possible to expedite processing of requests.

What can I do to help my request for a change get processed quickly?

You can take a number of steps that greatly add to the speed with which program staff can process your request for a change to a project. Although most of them seem minor, multiplied over thousands of grants, such small items add up to great gains in efficiency and help program staff and your project’s staff work together more effectively. For example:

• Always use your PR/Award number. The PR/Award number gives program staff a great deal of information. We recommend you even put it on the outside of your envelopes so that, in the event your grant is reassigned to another staff person, your correspondence can be properly redirected before we even open the envelope. The PR/Award number is the only quick and accurate way we have to access your official file or your records in our data system. Always have it handy and leave it with any phone message as well.

• Always check your computations in budgets more than once. We recommend that you ask others on your staff to proof the math portions of your application and any other materials associated with your grant that you send to your program office. Computation errors are one of the major causes of delays in processing requests.

• Read carefully the attachments and enclosures that come with your GAN. The attachments and enclosures sent with your GAN contain important information that can simplify the administration of your grant with regard to receiving payment, sending required reports, and following special terms and conditions.

• When in doubt, ask. If you are not sure about something, do not hesitate to contact the program staff person assigned to your grant. That person is available to give technical assistance and to help you understand grant regulations and the award documents. Obtaining guidance can ensure that your documents are complete the first time you submit them so you can avoid unnecessary paperwork.

Do OMB circulars apply to my grant award?

Yes. The Office of Management and Budget, in the Executive Office of the President, issues OMB circulars. OMB circulars are guidance for federal departments and agencies on a variety of topics. Some circulars establish federal policy on matters of grant administration, for example how to handle certain grant costs and audit requirements for grantees. OMB Circulars apply to Department of Education grant awards because the Department has adopted them in EDGAR. Information about obtaining OMB circulars is given in the section, Other Information, which begins after the Glossary section of this publication.

How do I make sure that I am complying with the regulations that apply to my award?

Carrying out the activities of your project in a way that is consistent with the requirements of federal regulations is a process that begins before you receive a GAN. It begins with the application process. You should make yourself familiar with EDGAR, and in many cases, the program regulations when you are filling out the required forms and preparing your application for submission to the Department. You can find program regulations in the application materials that the Department originally sent to you. EDGAR is available electronically on the Department’s Web site. Generally, we will also send you a copy of EDGAR if you receive a new award. EDGAR contains most of the administrative requirements applicable to your grant. Refer to the table of contents at the beginning of each part of EDGAR and the program regulations to help you locate specific information of interest to you. If you still have questions after reading the regulations, contact the program staff person handling your grant.

How does the Department know how my project is doing?

The Department monitors your project to determine how it is doing. Monitoring is an integral part of grant administration and oversight after a grant has been awarded. Its goal is to guide grantees to successful completion of their projects. Furthermore, the Department monitors grants in the spirit of partnership with a primary focus on performance and demonstrable results. Monitoring activities can take many forms including fiscal monitoring (i.e., tracking cash draw downs), reviewing reports, technical assistance contacts, and site visits.

In selecting projects for a site visit, the Department chooses a representative sampling of grantees and projects across programs. There are numerous reasons for a site visit to a grantee’s location, most of them favorable. Grantees should view site visits as unique occasions that present an opportunity for staff members from the Department and project staff members to get to know one another better. Site visits permit the grantee to present information to the program staff about the project in greater depth and detail.

What do I need to do to prepare for a site visit?

Since the requirements and procedures of each program office vary, you should contact the program staff member assigned to your project for guidance on preparing for an announced site visit.

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