- 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 more quickly?
- What are OMB Circulars? Do they apply to my grant award?
- How do I make sure that I am complying with the regulations that apply to my award?
- Do grant team members visit my project?
- What do I need to do to prepare for a site visit?
Grantees often ask what is required for them to do their projects ‘right.’ 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 a 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 trying to do it ‘right.’ As your project progresses, you will undoubtedly think of others.
You have the following major responsibilities when undertaking a project funded by the Department of Education:
- performing the work promised in the application;
- exercising proper stewardship of federal funds;
- complying with all legal and regulatory requirements;
- demonstrating and/or measuring progress towards achievement of project goals; and
- reporting all required information to the Department
In addition, each award for a discretionary grant or cooperative agreement imposes specific responsibilities on a grantee, depending on the program from which you receive funding.
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 grant team. Recent amendments to EDGAR have given grantees greater flexibility in managing their projects and have reduced the need for prior written approval from the Department. Known as the ‘expanded authorities’ regulations, these amendments to Part 75 of EDGAR renew the Department’s emphasis on partnership with grantees by giving them more autonomy in carrying out the activities of their projects. The new provisions permit grantees to undertake the following administrative actions without seeking prior approval from their grant team although, in some cases, a routine notification to the Department might still be required:
- extend the grant at the end of the project period for a period of up to one year;
- carry funds over from one budget period to the next;
- obligate funds up to 90 days before the effective date of the grant award; and
- transfer funds among budget line items. Grantees are urged to contact their grant team to get full details of the requirements.
The amendments significantly reduce regulatory and administrative burdens and give grantees more flexibility in planning and implementing program activities, provided that all administrative actions are consistent with the approved goals and objectives for the project, the program regulations, EDGAR, and OMB cost principles. If you are still not certain whether prior approval is required after reading the regulations, contact the grant team member shown on your Grant Award Notification 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 full extent allowable. However, if prior approval is required, you need to send your request by e-mail, fax, or regular mail to your grant team. Changes that require prior approval might take up to 30 days to process. The grant team will provide a written statement regarding the approval or disapproval of your request. Grantees are urged to use electronic communications such as e-mail and faxes as much as possible to expedite processing of their requests.
You can take a number of steps that greatly add to the speed with which grant teams 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 the grant team and your project’s staff to work together more effectively. For example:
- Always use your PR/Award number . Also called your ‘grant number,’ this number gives the grant team 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 grant team. Computation errors are one of the biggest causes of delays in processing requests.
- Read carefully the attachments and enclosures that came with your Grant Award Notification . The attachments and enclosures sent with your Grant Award +Notification contain important information that can simplify the administration of your grant in regards 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 a grant team member assigned to your grant. That person is here to give technical assistance and to help you understand grant regulations and the award documents. Their guidance can ensure that your documents are complete the first time so you can avoid unnecessary paperwork.
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. It is important for you to remember that OMB circulars apply to Department of Education grant awards only when the Department adopts them in regulations that specifically govern the Department. (Information about obtaining OMB circulars is given in the section, 'Other Information,’ which begins after the ‘Glossary’ section of this booklet.)
Carrying out your project in a way that is consistent with the requirements of federal regulations is a process that begins before you even receive a Grant Award Notification. It begins with the application process. You should make yourself very familiar with the program regulations when you are filling out the required forms and preparing your application for submission to the Department. You can find these regulations in the application materials that the Department originally sent to you. As time passes, we encourage you to develop the same knowledge of the administrative regulations found in the copy of the EDGAR book mailed to you with your Grant Award Notification. EDGAR is also available on the Department’s Web site. The table of contents at the beginning of each part of these regulations helps you locate the area(s) of interest to you.
If you still have questions after reading through the regulations, call the grant team member whose telephone number appears on your Grant Award Notification under the line that reads ‘Education Program Contact.’ If that person is not available, you can talk with the authorized official who signed your Grant Award Notification.
There is no way to predict exactly which grantees will receive a site visit from the Department. However, since the Department has limited resources for travel and makes almost 8,000 awards for discretionary grants and cooperative agreements each fiscal year, the likelihood that any particular grantee will receive a site visit in any given year is very small.
There also seems to be some misunderstanding among grantees that the Department chooses only ‘troubled’ projects for site visits. Nothing could be further from the truth! Ideally, the Department seeks to make site visits to 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 which 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 grant team about the project in greater depth and detail.
Since the requirements and procedures of each program office vary, you should contact the grant team member assigned to your project for guidance on preparing for an announced site visit.