Discretionary Post-Award Requirements
For more information regarding the post-award requirements for discretionary grants awarded through the Administration for Children and Families (ACF), please review the following topics:
Terms and Conditions
Grantees must adhere to the following terms and conditions:
- Administrative and National Policy Requirements
- Award Term for System Award Management and Unique Entity Identifier
- Award Term for Federal Financial Accountability and Transparency Act (FFATA) Subaward and Executive Compensation Reporting Requirement
- Award Term and Condition for Recipient Integrity and Performance Matters (Commonly referred to as FAPIIS)
In addition, the Department of Health and Human Services (HHS) Grants Policy Statement (GPS) is the policy guide for discretionary grants and cooperative agreements. It became effective October 1, 2006 and is applicable to all Operating Divisions (OPDIVS), such as 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.
For grantees that have awards that involve property, the following terms and conditions must be adhered to:
Please also review the Notice of Award (NoA) and NoA Remarks to familiarize yourself with the specific Terms and Conditions that apply to your particular grant program. The NoA is the legal document issued from ACF to the receiving organization that indicates an award has been made.Next: Reporting >
Performance Progress Reports (PPR)
ACF grantees must consult their Notice of Award (NoA) documents to determine the appropriate PPR format required under their award. Consistent with the Paperwork Reduction Act of 1995, 44 U.S.C. §§ 3501-3521, grantees are not required to respond to a collection of information covered by such Act, unless it displays a current valid Office of Management and Budget (OMB) control number. Unless otherwise approved by OMB, grantees are to complete the SF-PPR ACF Performance Progress Report. PPRs are due 30 days after the end of the reporting period. Final program performance reports are due 90 days after the close of the project period.
Federal Financial Reports (FFR)
ACF grantees are required to use the SF-425 Federal Financial Report for expenditure reporting. SF-425 reports are due as frequently as is required in the terms and conditions of award using due dates from reports to the HHS Payment Management System (PMS). Grantees will continue to submit the FFR Federal Cash Transaction Report (FCTR) to HHS PMS.
PLEASE NOTE: Beginning with all FY 2016 new awards, both the SF-425 and FCTR forms must be submitted to HHS PMS. In this pilot, ACF and the HHS Program Support Center are collaborating in the submission of the SF-425 to reduce the burden on grantees and to assist with the reconciliation of expenditures and disbursements to support the timely close-out of grants.
All expenditure reports will be due on one of the standard due dates by which cash reporting is required to be submitted to PMS or at the end of a calendar quarter as determined by ACF. As a result, a recipient that receives awards from more than one Federal program may be subject to more than one approach, but will not be required to change its current means of submission or be subjected to more than eight standard due dates.
|For Budget Periods Ending in Months of:||The FFR (SF-425) and if applicable, the Real Property Status Report (SF-429 Attachment A) are due to ACF on:|
|January 01 through March 31||April 30|
|April 01 through June 30||July 30|
|July 01 through September 30||October 30|
|October 01 through December 31||January 30|
Further instructions will be provided in the NoA, as necessary, with award terms and conditions that will address specific reporting periods and due dates on an award-by-award basis. A final cumulative SF-425 is due 90 days after the close of the project period.
Federal Financial Accountability and Transparency Act (FFATA) Subaward and Executive Compensation
Awards issued by ACF may be subject to the Transparency Act subaward and executive compensation reporting requirements of 2 CFR Part 170. See ACF's Award Term for Federal Financial Accountability and Transparency Act (FFATA) Subaward and Executive Compensation Reporting Requirement implementing this requirement and additional award applicability information.
Tangible Property Report (SF-428)
ACF grantees that purchase any tangible personal property, equipment with a unit cost of $5,000 or more and residual supplies with an aggregate fair market value exceeding $5,000, are required to submit the Tangible Personal Property Form SF-428. The SF-428 is a standard form used to collect information related to tangible personal property.
As noted in the NoA, grantees are required to use the following forms: SF-428-A (Annual Report), SF-428-B (Final Report Form and Instructions),SF-428-C (Disposition Request/Report). A Supplemental Sheet (SF-428S) may be used to provide detailed individual item information.
Real Property Status Report (SF-429)
ACF grantees are required to submit the Real Property Status Report SF-429, if applicable. This collection of forms must be used for awards that establish a Federal Interest on real property.
In accordance with 45 CFR §75.343, ACF grantees (non-Federal entities) are required to submit status reports at least annually on real property in which there is a Federal interest. When real property is purchased, constructed or improved at a cost of at least $250,000 in Federal funds, a Federal interest is established. This interest does not expire. When a grant ends, the grantee can continue to use the property for purposes approved under the grant. But when the property is no longer needed, the grantee must request disposition instructions after which ACF will approve one of the three options prescribed under 45 CFR §75.318, eliminating the Federal interest. So long as a Federal interest remains, the title holding entity (i.e., a current or former grantee) must report on the property annually.
Beginning on July 1, 2017, the following OMB approved real property report and request forms, OMB Control Number: 3090-0296, are available electronically through the Online Data Collection System (OLDC). To access and submit the forms, please login to www.grantsolutions.gov and navigate to the forms. The step-by-step instructions and training recordings are housed in one of two places according to how you access the system, either under GrantSolutions Help/Support or OLDC News and Tips.
The standard report and requests are to be used by recipients of Federal awards to report real property status (Attachment A) or to request agency instructions on real property (Attachments B, C) that was/will be acquired (i.e., purchased, constructed or renovated) in whole or in part under a Federal Award. This form consists of the SF-429 Real Property Status Report (Cover Page) and three attachments as required in the terms and conditions of the award: SF-429-A ATTACHMENT A (General Reporting), SF-429-B ATTACHMENT B (Request to Acquire, Improve or Furnish), or SF-429-C ATTACHMENT C (Disposition or Encumbrance Request).
The annual SF-429 Attachment A due date is the same as the annual SF-425 Federal Financial Report (FFR), which is “on the quarterly reporting date for the quarter in which the grantee’s budget period ended.” Whereas, the SF-429 Attachment B and C must be submitted for prior approval before a recipient acts on acquisition, disposition, or encumbrance of a property.Next: Internal Controls >
Effective Internal Controls are the basis for strong financial systems, programmatic oversight and processes that prevent fraud, waste, and abuse and ensure federal stewardship of funds. Recipients of federal awards are required to follow one of two approved internal control frameworks: (1) the Government Accountability Office (GAO) Standards for Internal Control in the Federal Government (“Green Book”) or the (1) Community of Sponsoring Organizations (COSO) Internal Control – Integrated Framework. Both GAO and COSO provide a framework for designing, implementing, and operating an effective internal control system to achieve objectives related to:
- Operations - Effectiveness and efficiency of operations
- Reporting - Reliability of reporting for internal and external use
- Compliance - Compliance with applicable laws and regulations
Requesting Payment of Federal Awards
Awards issued from the Department of Health and Human Services are paid through the Payment Management Services, formerly known as the Division of Payment Management, operating under the Program Support Center (PSC). PSC provides automated grant payment and cash management services for grants issued by Federal Government Awarding Agencies. PSC operates the centralized payment system, Payment Management System (PMS), and acts as a liaison between the ACF to resolve any discrepancies.
If this is your first award through PMS, it is recommended that you review the information provided on their website for Grant Recipients. The Grant Recipient FAQs section provides basic information to frequently asked questions. It is mandatory that all new recipients complete and send to PSC a Direct Deposit Sign-Up Form (SF 1199A) and a PMS Access Form. For more information, please visit Domestic Banking Direct Deposit section.
PMS is a web-based system and funds are electronically deposited into the designated bank account on the next business day. Funds may be drawn as a reimbursement or to accommodate your immediate needs and must not be held in excess of three (3) working days. The payment method for state agencies shall be consistent with the Treasury/State CMIA agreements or default procedures codified under 31 CFR Part 205.
For assistance on navigating and/or responding to PMS user questions, the PMS Help Desk provides assistance to all system users.Next: Single Audit Requirements >
Single Audit Requirements
The Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) has been issued by the Office of Management and Budget (OMB).
HHS/ACF has implemented the Uniform Guidance at 45 CFR § 75.
According to the Subpart F-Audits 45 CFR §75.501(a) Non-Federal entities that expend $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. Guidance on determining Federal awards expended is provided in 45 CFR § 75.502.
The administrative requirements and cost principles are effective for new awards and to additional funding on existing awards as of December 26, 2014. The audit requirements apply to audits of organizations with fiscal years beginning on/after December 26, 2014. Existing awards that do not receive additional funding will continue to be administered by the terms and conditions in effect at the time of the original award.
ACF grantees are responsible for submitting their Single Audit Reports and the Data Collections Forms (SF-FAC) electronically to the to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt or nine months after the FY’s end of the audit period. The FAC operates on behalf of the OMB.
For specific questions and information concerning the submission process:
- Visit the Federal Audit Clearinghouse
- Call FAC at the toll-free number: (800) 253-0696
Grant Management Contacts
The ACF federal project officer (FPO) and grants management specialist (GMS) monitor grants to identify potential issues and areas where technical assistance might be necessary. They do this through reviews of reports and correspondence from the grantee, audit reports, site visits, and other information available to ACF.
For any questions related to your budget, fiscal reporting, and other administrative requirement questions, please contact your GMS identified on your Notice of Award (NoA).
Questions related to programmatic requirements and reports are to be directed to your FPO.