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Introduction
1. Understand why the Project Officers class was established.
2. Identify ongoing certification requirements.
3. Understand the inclusion of grants management in your performance standards.
4. Know what subjects will be covered in this text and what areas will not be covered.
5. Describe the different relationships between the key players in the assistance arena.
A large part of EPA's mission is accomplished by awarding extramural funds to other organizations to conduct environmental programs and or special projects. Approximately $4.5 Billion a year is provided through assistance agreements. The Project Officer (PO) plays a key role in assuring the proper expenditure of these funds.
EPA (and other Federal agencies) award funds through one of two methods
-- "acquisition" or "assistance." The basic difference
between acquisition and assistance is the relationship between the parties.
If an activity is funded to meet an internal EPA need, e. g., prepare a specific
report to Congress or purchase furnishings for EPA staff, then an acquisition
(contractual) relationship exists and EPA's direct procurement requirements
(e. g., the Federal Acquisition Regulations) apply. If the activity is funded
to primarily benefit someone other than the Federal government, e. g., build
a wastewater treatment plant, then an assistance relationship exists and
EPA's rules which apply to assistance programs apply. The latter is the subject
of this course.
In 1995, the Deputy Administrator for the Office of Administration and Resources
Management issued a directive that all Project Officers (PO) for assistance
and interagency agreements must be trained in awarding and managing those agreements.
Our focus is on the roles and responsibilities of the PO. When you complete
this class you will have:
- An overview of the issues and regulations related to the various types of agreements;
- Instructions on how to develop and manage assistance agreements;
- Examples of the types of documents you will develop using the Integrated Grants Management System (IGMS).
To serve as a Project Officer on an assistance agreement, you must complete
the training course using this manual or an approved Office of Grants and
Debarment (OGD) substitute manual, presented by an OGD approved trainer.
This course identifies the Core Competencies for EPA Project Officers managing
assistance agreements. Completion of this course serves as the only basis
for Project Officer certification. At completion of this course your name
and training information will be input into the "National Project Officer
Database."
To maintain your certification, you must take a refresher course within three
years after you complete the basic course, and every three years thereafter.
You will be notified by email 60 days before your certification expires. There
is an online option for the refresher requirement. Refresher classroom training
is offered on a very limited basis. If you let your current certification expire
you will be required to retake the basic class.
This manual gives you general guidance when the rules are subject to interpretation
(which they often are). Your own office may have different procedures, templates
for documents, etc., than those presented in this text. The information in
this manual will help you differentiate between policy and recommended practices
so you will know where you have some latitude. This manual provides guidance
relative to all types of assistance agreements and is designed to follow
the life of an assistance agreement from the planning stage through closeout
and audit if appropriate. In addition, key policy documents are incorporated
into the text for your convenience. Links to the regulations that apply to
assistance agreements and the corresponding OMB cost principles are included
for easy access.
EPA must ensure the resources allocated to the agency are spent according to
policies, guidelines, etc., and achieve maximum value. Each assistance agreement
has its own set of rules. You will find that some rules are universal (e.g.,
ethics) while others are unique to the type of agreement. When in doubt, refer
to this manual for a quick reference or ask the person in your office who is
assigned to assist PO's.
Performance Standards for Assistance Project Officer
In November 2003, the Deputy Administrator for the Office of Administration
and Resources Management issued a directive for all Senior Resource Officials
(SROs) to initiate a review of current performance standards and position descriptions
for all non-SES employees involved in grants management to ensure that the
complexity and extent of their grants management duties are accurately reflected.
This request includes the management of both grants and cooperative agreements.
- Once you are a PO you must establish performance standards specific to the type of agreement you will be assigned to manage. Some latitude in establishing performance standards exists. Your office may have templates for standards.
The next section is a brief summary of the players in the assistance arena that you will need to be aware of as you move thru the "cradle to grave" process of grants management.
Assistance Team
Project Officer
The Project Officer (PO) is the EPA official who provides technical and programmatic oversight and who is designated in the assistance agreement as EPA's program contact with the recipient. The PO is responsible for ensuring assistance agreements meet scientific, technical, and programmatic requirements. Proper stewardship of Federal funds depends on the efforts of the PO to determine the appropriateness and technical merit of proposals, as well as monitoring and overseeing projects. The PO must also work with recipients to identify "Environmental Outcomes" in the work plans of the assistance agreements they manage. The PO is critical to the successful completion of work performed under an assistance agreement. Many decisions and recommendations, including some administrative decisions, can be made only by persons with programmatic expertise. Input from the PO is required in providing oversight and certifying the quality and acceptability of a recipient's programmatic performance.
Many people are involved in awarding and managing assistance agreements. As the PO, you have a very large role, but you are not alone. Other personnel will help you fulfill your responsibilities. EPA encourages a team approach from the planning stages through the closeout of the agreement.
Recommending Official
The Recommending Official is usually a Division Director, Branch Chief or Team
Leader in the program office who will recommend funding for an award. The Recommending
Official reviews new awards and some post-award packages for concurrence before
submitting them to the Approval Official. Recommending Officials are generally
managers in the chain-of-command between the PO and Approval Official. For
example, if the delegated Approval Official is the Division Director, then
the Recommending Official would likely be a Branch Chief. If the Approval Official
is the SRO, then the Recommending Official would likely be the Lab, Center
or Office Director.
Approval Official
The Approval Official is an EPA official delegated the authority to approve or reject an application and to approve the technical and programmatic terms and conditions on proposed assistance projects. The Approval Official (sometimes referred to as the Decision Official) is the program individual with the responsibility and authority to decide whether to fund or reject an assistance or interagency agreement for technical or programmatic reasons. Approval Officials approve certain agency documents and ensure that all technical, legal, and administrative matters are correct from a programmatic point of view. Based on the dollar amount and length of the agreement, different program officials are delegated authority to approve funding packages.
Senior Resource Official (SRO)
The SRO is a Senior Executive Service manager who reports directly to the
Assistant, Associate, or Regional Administrator. SROs are typically the Deputy
Assistant Administrators and the Assistant Regional Administrators. The SRO
is accountable for that Office's ethical, effective resource management,
including acquisition, assistance, and programmatic financial management.
The Senior Resource Official (SRO) oversees and guides the resource management
activities within their respective organization. SROs are EPA's primary points
of accountability. They maintain fiscal resource management practices (EPA
Order 1130.2A "Senior Resources Officials and Resource Management Committee").
EPA Order 1130.2A dictates levels of SRO approval. However, many programs
and Regions have lowered that level so check with your Program for their
level of SRO concurrence.
Quality Assurance Manager
The Quality Assurance Manager (QAM) foster the highest quality research by
or on behalf of the agency. QAMs are located in each office as well as in some
divisions. QAMs assist you in setting the QA requirements for assistance agreements
and in ensuring the requirements are met. The QAM reviews proposed assistance
applications to decide if the requirements of EPA Order 5360.1A2 (Policy and
Program Requirements for the Mandatory Agency-wide Quality System) apply and
if so, how they can be implemented.
Funds Certifying Official
The Funds Certifying Official (FCO) is located in each Program office. The
FCO certifies the availability of funds to be used on the agreement by considering
the correct purpose, time and amount.
Grants Competition Advocate (GCA)
The Grants Competition Advocate is an official located in the Office of Grants
and Debarment responsible for overseeing the implementation of the Policy for
Competition in Assistance Agreements, EPA Order 5700.5.
Grants Specialist
The Grants Specialist within the Grants Management Office (GMO) serves as EPA's
administrative contact with the assistance recipient. Grants Specialists (GS)
provide administrative guidance and direction. They will review and approve
the administrative portion of the assistance application and prepare the assistance
agreement and any formal amendments. Additionally, they monitor the agreement
for compliance with administrative conditions and help the PO resolve performance
problems. Lastly, they close out the agreement after all the terms and conditions
are fulfilled.
Award Official
The Award Official is the EPA official with the delegated authority to
sign assistance agreements and to take other actions authorized by EPA regulations
and by EPA Orders. At Headquarters the Award Official is the person that
the Grants Administration Division (GAD) assigns to control the spending
of funds under assistance agreements. This official signs the agreement ensuring
that all technical, legal, and administrative evaluations are made and that
the proposed agreement meets all requirements for award. In the regions the
Award Official could be located either in the Grants Management Office or
the Program. As a PO you will have the responsibility of learning your office's
business practices. The Award Official must be assured from both the programmatic
and management perspectives of the appropriateness of decisions concerning
applications and awards. The Award Official relies on the advice, guidance,
and recommendations of both the program office (primarily through the PO)
and the GMO.
Grants Management Office (GMO)
The GMO is responsible for full "cradle to grave" management of financial assistance agreements and interagency agreements.
Office of General Counsel (OGC)
OGC provides legal opinions, legal counsel and assists in the formulation of policies and programs. OGC specifically supports Program offices by helping to interpret statutes and regulations (such as the Clean Air Act) and to provide advice on such issues as "acquisition vs. assistance."
Working together as partners, EPA's program and management officials approve, award, and manage assistance agreements.
At the beginning of the chapter, we identified several objectives you would accomplish after reading the chapter. The objectives are listed below, each followed by a brief summary of the key points the chapter covered.
1. Understand why the Project Officers class was established. In 1995, the Deputy Administrator for the Office of Administration and Resources Management issued a directive that all Project Officers for assistance and interagency agreements must be trained in awarding and managing those agreements. This was after continued ongoing scrutiny by the OIG, GAO and the Congress of the United States. The oversight by these groups continues today.
2. Identify ongoing certification requirements. To serve as a Project Officer
on an assistance agreement, you must complete the training course using this
manual, presented by an Office of Grants and Debarment (OGD) approved trainer.
To maintain your certification, you must take a refresher course within three
years after you complete the basic course, and every three years thereafter.
3. Understand the inclusion of grants management in your performance standards.
As directed by the November 2003 memo, once you are a PO you must establish
performance standards specific to the type of agreement you will be assigned
to manage.
4. Know what subjects will be covered in this text and what areas will not be covered. This manual provides guidance relative to all types of assistance agreements and is designed to follow the life of an assistance agreement from the planning stage thru closeout and audit if appropriate. This course will not provide specific PO programmatic and technical requirements. That is a responsibility of the National Program Manager (NPM) for each program.
5. Describe the different relationships between the key players in the
assistance arena. Working together as partners, EPA's program and management
officials approve, award, and manage assistance agreements.
The program office is responsible for ensuring assistance agreements meet scientific,
technical, and programmatic requirements; the GMO is responsible for the cradle
to grave administration of EPA assistance agreements and interagency agreements.
1. Distinguish between the Approval Official and the Award Official.
2. Distinguish between the SRO and the Approval Official. Why might SRO's approval thresholds be different?
3. Compare and contrast the Project Officer's and Grant Specialist's responsibilities.
4. Describe why the PO is critical to the successful completion of work performed under an assistance agreement.
5. Who does the Award Official rely on for advice, guidance, and recommendations?