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PRE-AWARD COMPLIANCE FOR NON-PROFIT ORGANIZATIONS

PRE-AWARD COMPLIANCE FOR NON-PROFIT ORGANIZATIONS

EPA assistance awards (grants and cooperative agreements) to non-profit organizations are an important mechanism for delivering environmental protection to the public. EPA's Office of the Inspector General, however, has issued numerous audit reports documenting instances of non-profit recipients that have inadequate administrative systems to manage EPA funds or lack the capability to successfully perform the project scope of work. The Office of Grants and Debarment has identified similar issues in conducting post award monitoring activities.

Recognizing that it is preferable to address such issues before, rather than after, an assistance agreement is awarded; EPA has begun evaluating the administrative and programmatic capability of non-profit applicants.

These procedures are based on existing regulatory requirements. Specifically, 40 CFR § 30.14 authorizes EPA to impose pre-award conditions on a non-profit applicant that has a history of poor performance, is not financially stable, has a management system that does not meet the standards prescribed in 40 CFR Part 30, has not conformed to the terms and conditions of a previous award, or is not otherwise responsible. Further, 40 CFR § 30.62 provides EPA with remedies to deal with non-profit recipients that mismanage assistance agreements either administratively or programmatically. Finally, under 2 CFR Part 180 and Part 1532, EPA may suspend or debar non-profit applicants or recipients that pose a serious business risk to the Government.

After receiving notification from the Program Office that an application has been recommended for funding, the Grants Management Office (GMO) must: require the applicant to fill out the Administrative Capability Form contained in Appendix A to the EPA Order and provide supporting documents; and then conduct a review of this information. If the GMO, based upon a review of the completed Administrative Capability Form and after checking the Grantee Compliance Database, determines that the applicant lacks the necessary administrative capability, the award official must impose pre-award conditions under section 10(b), or special award conditions under Section 10(d), of the EPA Order. If the GMO finds that the applicant has the necessary administrative capability, pre-award or special award conditions are not required.

| Application Kit for Federal Assistance | Letter to Applicant | Applicable EPA Regulations and Description | Grant Application Forms | EEO Contacts | Checklist for Applications | Official Mailing Addresses | On-Line Grant Application Kit |
| Appendix D: Fact sheet for Applicants Intergovernmental Review Process | Accessibility
| Return to the Grants and Debarment Home Page |


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