grant-compliance-check

Purpose

After award, translate the notice of award, agreement, and applicable cost principles into a calendar and control list so the city does not lose funds to avoidable noncompliance. Federal awards are governed by the Uniform Guidance (2 CFR 200) plus program rules; state and foundation grants have their own terms. Always read the award document: its special conditions override general assumptions.

Required inputs

• Award notice, grant agreement, application and approved budget, and any amendments.
• Identification: federal vs. state vs. private; assistance listing number and pass-through entity if federal; award period of performance.
• Match/cost-share commitments and their sources (cash vs. in-kind).
• Existing city policies: procurement, time-and-effort, travel, conflicts of interest, records.
• Staff roles: project manager, finance, grants coordinator.

Workflow

1. Classify the award and confirm which rule set applies. For federal funds, determine which version of 2 CFR 200 applies based on award date and note the revised thresholds (for example, the equipment definition, de minimis indirect rate, and Single Audit threshold changed for awards and fiscal years on or after October 1, 2024; verify current figures).
2. Determine subrecipient vs. contractor relationships for any funds passed on (2 CFR 200.331) and the monitoring duties that follow.
3. Build the compliance calendar: financial and performance report dates, drawdown rules (payment timing and minimizing cash on hand), closeout deadline, Single Audit applicability (expenditures of federal awards at or above the threshold), and records retention (generally three years from final financial report under 2 CFR 200.334, longer if audit or litigation is open).
4. Allowable costs: test the budget against allowability, allocability, and reasonableness (2 CFR 200 Subpart E), prior approval requirements, and indirect cost treatment (negotiated rate or de minimis).
5. Match: confirm source is eligible (cannot be federal funds unless allowed), documented, timely, and not double-counted on another award. In-kind valuation needs documentation.
6. Procurement: apply the stricter of federal and local procurement rules (2 CFR 200.317-200.327), including micro-purchase and small-purchase thresholds as adopted, competition, cost or price analysis, suspension and debarment checks (SAM.gov), and required contract provisions (Appendix II). Add Buy America or domestic preference clauses if the program requires.
7. Other overlays: Davis-Bacon, Build America Buy America, environmental review (NEPA), Uniform Relocation Act, Title VI, Section 504/ADA, lobbying certification, and program-specific rules.
8. Internal controls: separate approval, payment, and reconciliation; time-and-effort certifications; equipment inventory; and a risk-based monitoring plan for subrecipients.

Output structure

| Requirement | Source (agreement section / CFR cite) | Owner | Due date or trigger | Evidence to retain | Status |

Add: match tracker, allowable-cost exceptions list, procurement checklist, and risk rating (low/med/high).

Red flags / escalate

• Costs incurred before the period of performance or without required approval.
• Match source not secured or already committed elsewhere.
• Missing SAM.gov registration or suspension/debarment checks.
• Unclear subrecipient vs. contractor status.
• Late reports or advances held beyond rules.
• Findings suggesting fraud or misuse: notify the city attorney and the awarding agency per terms.

Common mistakes

• Treating the application budget as the compliance document.
• Spending ahead of an executed agreement.
• Failing to track in-kind match.
• Applying only local procurement thresholds.
• Discarding records at the local retention date while the award requires longer.

State-law variance

State grant programs and pass-through entities may impose stricter rules. Cite only what the award text or counsel confirms.