If your organization receives federal grant funds, make sure you are familiar with the Code of Federal Regulations (C.F.R.) Title 2. You could literally write volumes of encyclopedias with the information contained in the C.F.R. So it’s imperative that you develop a working knowledge of them, how to find the codes that pertain to your particular grant program, and where to find assistance.
My Best Advice
Federal Grant Awards are both rewarding and demanding, carrying an enormous responsibility. In contrast, many Foundation grants have minimal requirements. The Notice of Funding Opportunity (NOFO) often identifies the C.F.R. Numbers that you will adhere to. For example, here’s an excerpt from the FEMA Fire Prevention and Safety Grant, FY 2018:
“Disclosing Information per 2 C.F.R. § 180.335
This reporting requirement pertains to disclosing information related to government-wide suspension and debarment requirements. Before a recipient enters into a grant award with FEMA, the recipient must notify FEMA if it knows if any of the recipient’s principals under the award fall under one or more of the four criteria listed at 2 C.F.R. §180.335. At any time after accepting the award, if the recipient learns that any of its
principals falls under one or more of the criteria listed at 2 C.F.R. §180.335, the recipient must provide immediate written notice to FEMA in accordance with 2 C.F.R. § 180.350.”
FY 2018 FP&S NOFO, https://www.fema.gov/media-library-data/1541719302077-037d0f7af75cbf04ae289deabdd15a0a/FY18FPSNOFO.pdf
In case you’re wondering exactly what 2 C.F.R. § 180.335 states:
“§180.335 What information must I provide before entering into a covered transaction with a Federal agency?
Before you enter into a covered transaction at the primary tier, you as the participant must notify the Federal agency office that is entering into the transaction with you, if you know that you or any of the principals for that covered transaction:
(a) Are presently excluded or disqualified;
(b) Have been convicted within the preceding three years of any of the offenses listed in §180.800(a) or had a civil judgment rendered against you for one of those offenses within that time period;
(c) Are presently indicted for or otherwise criminally or civilly charged by a governmental entity (Federal, State or local) with commission of any of the offenses listed in §180.800(a); or
(d) Have had one or more public transactions (Federal, State, or local) terminated within the preceding three years for cause or default.”
2 C.F.R. “§180.335 https://www.ecfr.gov/cgi-bin/text-idx?SID=18fff07f1f13fe289de58700f0cef54d&node=2:126.96.36.199.188.8.131.52&rgn=div8
If after reading the above you become confused, fear not! Terminology can be overwhelming, but you can always find definitions online. The first time I read this a several years back, I had to look up the definition of “covered transaction”. It gets easier the more you read.
Here’s the best advice I can provide for keeping your thoughts organized when managing a federal grant award:
- While reading the Award Letter and/or Notice of Funding Opportunity, locate each C.F.R. Number that is identified.
- Print the code(s) and read carefully, highlighting any portion you either do not comprehend or may pertain to your organization.
- Every Federal Grant recipient is assigned a Federal Grant Manager, your valued assistant. It is his or her purpose to provide answers and help you be compliant. Do not hesitate to contact your program manager, pointing out the items you highlighted.
- In life, there are some instances where it’s better to plunge ahead and ask forgiveness later….but a Federal Grant Award is NOT one of those instances. It is always better to ask and not assume.
- After managing a few Federal Awards, you’ll be much more comfortable with C.F.R. “lingo”.
- Finally, let me know how I can help! Contact me here.