Post Award Guidance for Grantees

• Semi-Annual Reporting
• Other Post-Award Requirements
  • Annual Federal Financial Reports (FFRs)
  • Quality Assurance (QA)
  • Minor Project Updates
  • Other Monitoring Activities (as required)
• Project Change Requests
  • No-Cost Time Extensions
  • Project Work/Scope Change
  • Project Budget Change
• Close-Out Procedures
  • Financial Close-Out
  • Programmatic Close-Out

Semi-Annual Reporting

Exchange Network grantees must submit semi-annual reports two times a year, during their grant's period of performance. The first reporting period is October 1st - March 31st, with a progress report due by April 30th, and the second reporting period is April 1st - September 30th, with a progress report due by October 31st.

All EN grantees, including recipients of performance partnership grants (PPGs), must register for their grant following their Notification of Award (NOA). Reports are submitted electronically through EPA's Central Data Exchange (CDX).  To register for a CDX account, grantees must visit the CDX website and complete the steps required for registration. A training PowerPoint presentation is available for grantees submitting semi-annual progress reporting forms through CDX and can be found at the CDX website Frequently Asked Questions page. 

For a grant's first report, grantees will need to list all goals and outputs from their final approved project work plan (as included in the award document), along with scheduled output completion dates. Please note that these fields in CDX are now editable by the reportee (NEW IN FY25!), but they must contact their project officers (POs) in advance to ensure the edit is necessary (e.g., updates to project goals and outputs following an approved change request). A project officer will automatically reject a report that has edited fields, if prior approval was not given. 

At a minimum, semi-annual progress reports must include in the "Progress and Status" reporting field:

1. An update on the schedule and status of carrying out the project, including any problems encountered and suggestions to overcome them;
2. An explanation of expenditures to date, with expenditures linked to project results;
3. Information on each of the following areas: 
   1. A comparison of accomplishments to the outputs/outcomes established in the assistance agreement work plan for the reporting period; 
   2. Explanations on why established outputs/outcomes were not met (if applicable); and
   3. Additional information, analysis, and explanation of cost overruns or higher-than-expected-unit costs. Please submit reports as soon as possible before the end of month to allow time for any needed revisions prior to the due date. Semi-annual reports must be submitted even when progress has not been made during the reporting period!
4. If applicable, semi-annual reports must also address subawards; grantees should coordinate with their subawardees (formal EN partners or mentors) in advance of reporting periods, to ensure that subawardee updates are included in the report.

Reports lacking clarity or sufficient detail will be rejected by their project officer; grantees should edit their rejected report and resubmit to their project officer ASAP to ensure an 'on-time' progress report for that reporting period.

For any questions on semi-annual reporting, please contact your EPA project officer, also known as a Regional Exchange Network Coordinator (RENC). 

Other Post-Award Requirements

Annual Federal Financial Reports (FFRs)

Pursuant to 2 CFR 200.328, EPA recipients must submit the Federal Financial Report (SF-425) annually, unless a greater reporting frequency has been communicated by the project officer.

To complete the annual FFR:

1. Grantees should prepare and submit a SF- 425 Federal Financial Report (FFR) to EPA's RTP Finance Center by the end of each calendar year (unless otherwise specified by the project officer).
   1. This report should be submitted electronically via email at rtpfc-grants@epa.gov.  However, if that is not a valid option, please mail the report to: US Environmental Protection Agency, RTP-Finance Center (Mail Code AA216-01), 4930 Page Road, Durham, North Carolina 27703.
2. EPA will review and approve the submitted FFR.

Quality Assurance (QA)

Quality Assurance documentation may be required for awarded projects, due within 90 days of the award. See the Quality Assurance (QA) Document Submittal Requirements.

Minor Project Updates

Grantees should submit updated grantee attachments, such as updated indirect cost rate agreements and revised Key Contact Forms, as applicable through the life time of their grant project to their project officers (RENCs). Grantees should reach out to their project officer if they are unsure if a revised grantee form is needed, as relates to a project or organizational change.

Other Monitoring Activities (as required)

Grantees should respond in a timely manner to any project status update requests by their project officer (RENC), grant specialist, or any EN grant program contacts at EPA HQ. Grantees are asked to accept meeting invites by their project officers, when requested, to ensure that their POs can accurately complete annual monitoring activities, such as annual baseline reports and advanced monitoring assignments. To the extent possible, EPA will work with grantees to ensure that coordination calls and information requests align with grantee availability and will strive to minimize administrative reporting burden, whenever possible.

Project Change Requests

No-Cost Time Extensions

Exchange Network assistance agreements have a standard period of performance (POP) of three years. Requesting a no-cost time extension extends the period of performance by one year. Grantees can request up to four no-cost time extensions, for a total POP of up to seven years.

No-cost time extensions should be requested three to six months prior to the expiration of the grant's POP, when it is clear to the grantee that project work will not be completed by that time. In some cases, extensions can be requested closer to the POP end date (August or September), but this is subject to project officer (PO) approval.

To submit a no-cost time extension request:

1. Grantees should reach out to their project officer (RENC) to inform them of the upcoming extension request.

2. Grantees should then revise their latest approved project workplan to include revised goal and output completion dates, reflecting the extended period of performance. Include, as applicable, an indication of any goals and outputs that have been completed, to date.

   Recommended Format for Submittal

   Project Goal	Project Output	Original Scheduled Output Completion Date	Actual/Revised Scheduled Output Completion Date	Comments
   1. [Goal Title]	1.1 [Output Title]	[mm/dd/yyyy]	[mm/dd/yyyy]	[Enter relevant comments/notes]
   	1.2 [Output Title]	[mm/dd/yyyy]	[mm/dd/yyyy]	[Enter comments…]
   	1.3 [Output Title]	[mm/dd/yyyy]	[mm/dd/yyyy]	[Enter comments…]

3. On agency letterhead, grantees should write a brief summary of the extension request and a description of why additional time is necessary to complete the project (e.g., explain the cause of past project delays). 
4. Grantees should email the updated project workplan (2) and the request letter (3) to their project officer/RENC. 
   1. If the project officer returns comments on either document, grantees should address these and resubmit ASAP.
5. Project officers will then seek HQ approval of the extension. 
6. If/when approved by HQ, the PO will then process the change request in EPA's grant system. Grantees can expect to receive confirmation of their extension via an updated award document in approximately 2-4 weeks. The semi-annual reporting cycle continues as normal.

Project Work/Scope Change

Grantees can request a change to their approved work plan commitments (goals and outputs) and/or the general scope of project work following award, but this is subject to EPA review and approval. Appropriate justifications for a scope or project work change must be provided, in sufficient detail, in order for the request to be considered. An example of an appropriate work change would be a change in the implemented data flow, following the discontinuation of the service by EPA and in alignment with updated EPA guidance.

To submit a project work/scope change request:

1. Grantees should reach out to their project officer (RENC) to inform them of the upcoming change request.
2. Grantees should then revise their latest approved 10-page project narrative to reflect the change, including the project workplan in Section Two: Project Goals, Outputs, and Outcomes.
3. On agency letterhead, grantees should write a brief summary of the project work/scope change request and a detailed description of why this change is being requested and the anticipated benefits of the modification. 
4. Grantees should email the updated project narrative (2) and the request letter (3) to their project officer/RENC. 
   1. If the project officer returns comments on either document, grantees should address these and resubmit ASAP.
5. Project officers will then seek HQ approval of the project modification. Note that a scope/project work change request requires additional levels of approvals, beyond the EN Grants program manager, and this may take up to 8 weeks.
   1. Meetings may be scheduled with the EN Grant Program Office, program management, and/or technical subject matter experts at EPA at this stage.
6. If/when approved by HQ, the PO will then process the change request in EPA's grant system.
7. Grantees can expect to receive confirmation of their amendment via an updated award document in approximately 2-4 weeks. Grantees can initiate work under the new approved workplan, following this confirmation.

Project Budget Change

Actual projects costs are expected to differ slightly compared to the original approved budget, as project realities often differ from original projections due to fluctuations in service, implementation, and product costs. Approved organizational rates such as fringe and indirect costs may also change in the lifetime of a project, and (assuming these changes are not significant) grantees should just submit their updated rates to their project officer, for upload to their grant's official EPA record. However, if any changes amount to 10% or more of the total award, or if cumulative changes over time reach this threshold, a formal amendment is required to update the approved project budget. Please note that all budget changes must result in a project total that exactly equals the original approved award amount.

To submit a project work/scope change request:

1. Grantees should reach out to their project officer (RENC) to inform them of the upcoming change request.
2. Grantees should then revise three application forms, to reflect the requested changes: 
   1. SF-424A 'Budget Information for Non-Construction Programs':
      1. In area '6. Object Class Categories' title a new column as "Fiscal Year ## Budget Revision"
      2. For each cost category, put the amount of money being added or removed. Money being added should be a positive value (e.g., $1000) and money being removed should be shown as a negative value (e.g., -$1000).

      3. Adjust the total of each cost category in the 'Totals' column (5).

         

   2. Project Narrative workplan
      1. Reflect any changes to costs across project goals, project outputs, and any other costs captured in this section, if applicable.
      2. A template for the project workplan is available in the Optional Project Narrative Template, under Section Two: Project Goals, Outputs, and Outcomes; see the Exchange Network Grant Program Resources section.
   3. Budget Narrative Attachment Form
      1. Reflect changes across budget cost categories, ensuring correct use of budget calculation formulas
      2. A template for the budget narrative attachment form is available in the Optional Budget Narrative Template; see the Exchange Network Grant Program Resources section.
3. On agency letterhead, grantees should write a brief summary of the project budget change request and a description of why this change is being requested.
4. Grantees should email the updated forms (2) and the request letter (3) to their project officer/RENC. 
   1. If the project officer returns comments on either document, grantees should address these and resubmit ASAP.
5. Project officers will then seek HQ approval of the budget modification.
   1. Email coordination and/or meetings with the EN Grant Program Office may be needed at this stage, in the case of clarifying questions and/or corrections to budget calculations or cost categories.
6. If/when approved by HQ, the PO will then process the change request in EPA's grant system.
7. Grantees can expect to receive confirmation of their amendment via an updated award document in approximately 2-4 weeks.

Close-Out Procedures

Once work has concluded or if a project's period of performance (POP) is ending without an option for further no-cost extensions, the grantee should begin their financial and programmatic close-out steps. Though close-outs typically align with the EN's standard POP, and are therefore initiated around September 30th of each year, grantees can request to close out their grant at any time once project goals and outputs are complete. Grantees also have the option to terminate projects early, even without the full completion of project work, although this should be discussed with project officers prior to the initiation of formal close-out steps. Please note that grantees are obligated to return any unspent funds to EPA and must also comply with equipment disposition requirements in accordance with 2 CFR 200.313, if applicable.

Grantees are asked to confirm with their project officers (RENCs) via email 3-6 months prior to their POP end date that they are intending to close-out their project (if more time is needed, please see the No-Cost Time Extensions section).

Once grantees have notified their project officer of their upcoming close-out, grantees must coordinate with the appropriate parties at EPA to fully complete both financial and programmatic close-out steps, within 120 calendar days of the POP end date or the initiation of grant close-out procedures.

Financial Close-Out

Financial close-outs are coordinated through EPA's Research Triangle Park (RTP) Finance Center (not through the project officer). Grantees should look for an email from EPA's Research Triangle Park (RTP) Finance Center, approximately 90 days before your grant is set to expire (July-August, as the EN Grant Program's standard POP ends on September 30th).

To complete financial close out: 

1. Within 120 calendar days of the POP end date, grantees should prepare and submit a final SF- 425 Federal Financial Report (FFR) to EPA's RTP Finance Center.
   1. This report should be submitted electronically via email at rtpfc-grants@epa.gov.  However, if that is not a valid option, please mail the report to: US Environmental Protection Agency, RTP-Finance Center (Mail Code AA216-01), 4930 Page Road, Durham, North Carolina 27703.
2. EPA will review and approve submitted FFRs.
   1. Final FFRs must indicate the exact balance of expenditures. All obligations must be fully paid at the time of close-out, and FFR should reflect no unliquidated obligations (ULOs).
   2. Grantees are responsible for maintaining an approved indirect cost rate agreement during the lifetime of their grant, if indirect costs are included in the approved project budget. If funds have been drawn down in excess of the approved rate and amount at any time during the grant's POP, these amounts may be deemed unallowable and result in repayment of funds to EPA.
3. If any errors or discrepancies are identified during EPA review of the final FFR, the recipient will be notified and instructed to submit a corrected report.
   1. Grantees should address any comments and resubmit the form ASAP, to ensure the form is approved within the allowable 120 calendar days.

Programmatic Close-Out

The programmatic close-out of EN assistance agreements includes the submittal and EPA approval of two forms: the final (technical) progress report and the IT Component and Project Registration Form, as submitted to the project officer (PO).

To complete programmatic close out:

1. Within 120 calendar days, grantees should prepare and submit a final progress report within EPA's CDX.
   1. Grantees should access their standard progress report template within EPA's CDX, as if they were submitting a semi-annual progress report, but should tick the box in the form to indicate that this is a final report.
   2. Grantees may submit this form in place of their regular progress report at the end of their project's POP or may elect to submit this form outside of the normal fall reporting period, as long as it is within 120 calendar days of the grant's close-out process initiation.
   3. The final report shall document project activities over the entire project period and shall include information on each of the following areas:
      1. a comparison of actual accomplishments with the anticipated outputs/outcomes specified in the assistance agreement work plan;
      2. the reasons why anticipated outputs/outcomes were not met (if applicable); and 
      3. other pertinent information, including, when appropriate, analysis and explanation of cost overruns or high unit costs.
2. EPA will electronically review and approve the submitted final (technical) progress report.
   1. If the project officer rejects the report with comments, grantees should address these and resubmit ASAP, to ensure the form is approved within the allowable 120 calendar days.
   2. Project officers will immediately reject any final reports that do not demonstrate sufficient detail and/or that do not reflect progress over the entire POP. 
3. Within 120 calendar days, grantees should prepare and submit via email to their project officer an 'IT Component and Project Registration Form', available as a fillable PDF on the Exchange Network Grant Program page Registration section.
   1. This form is unique to the EN Grant Program at EPA, and reflects a requirement as outlined within the EN programmatic Terms and Conditions; the completion of this form helps to build and maintain a network of environmental data exchange and IT solutions that promote the mission of EPA and its partners.
4. EPA will electronically review and approve the completed IT Component and Project Registration Form, ensuring all mandatory fields are populated in sufficient detail.
   1. If the project officer rejects the report with comments, grantees should address these and resubmit ASAP, to ensure the form is approved within the allowable 120 calendar days.
   2. Once approved, this form will be added to the Searchable IT Component and Project Registration Forms section of the EN website, as a potential resource for future EN grant applicants.
5. When both the final (technical) progress report (1) and the IT Component and Project Registration Form (3) are approved by the project officer, the PO will then submit a grant close-out certification. The appropriate grant specialist at EPA will then fully process the close-out in EPA's grant system.

For any questions on the close-out process or to confirm all requirements have been met, please contact your EPA project officer, also known as a Regional Exchange Network Coordinator (RENC).