PART 5

TECHNICAL ADMINISTRATION ACTIVITIES

5.1 Project technical representative Monitoring responsibilities
[1](#project-technical-representative-monitoring-responsibilities)

5.2 MONITORING TECHNICAL ACTIVITIES
[2](#monitoring-technical-activities)

5.2.1 General [2](#general)

5.2.2 BPA-Furnished Support [2](#bpa-furnished-support)

5.2.3 Recipient Progress Reports [2](#recipient-progress-reports)

5.2.4 Verify What the Recipient is Doing
[2](#verify-what-the-recipient-is-doing)

5.2.5 Document Contacts With Recipient
[3](#document-contacts-with-recipient)

5.2.6 PTR Status Reporting [3](#ptr-status-reporting)

5.3 MONITORING FINANCIAL Activities
[3](#monitoring-financial-activities)

5.3.1 General [3](#general-1)

5.3.2 Advance Payments [3](#advance-payments)

5.3.3 Reimbursement of Costs [4](#reimbursement-of-costs)

5.3.4 Review of Financial Status Reports
[5](#review-of-financial-status-reports)

5.3.5 Anticipated Overruns [6](#anticipated-overruns)

5.3.6 Disallowing Costs [7](#disallowing-costs)

5.3.7 Monitoring Program Income [7](#monitoring-program-income)

5.4 PROPERTY MANAGEMENT [7](#property-management)

5.5 MODIFICATIONS [7](#modifications)

5.5.1 Budget Changes [8](#budget-changes)

5.5.2 Requesting Approval for Changes
[8](#requesting-approval-for-changes)

5.5.3 Review and Approval of Request
[8](#review-and-approval-of-request)

5.5.4 Subrecipient Awards [9](#subrecipient-awards)

5.6 Extending the effective period of awards
[9](#extending-the-effective-period-of-awards)

5.7 POST-EXPIRATION COSTS [9](#post-expiration-costs)

5.8 REMEDIAL ACTIONS [9](#remedial-actions)

5.8.1 Determining if Remedial Action is Needed
[9](#determining-if-remedial-action-is-needed)

5.8.2 Initial Action When Award Requirements Are Not Being Met
[9](#initial-action-when-award-requirements-are-not-being-met)

5.8.2.1 Recipient Agrees With PTR [9](#recipient-agrees-with-ptr)

5.8.2.2 Recipient Disagrees With PTR [10](#recipient-disagrees-with-ptr)

5.8.2.3 Noncompliance [10](#__RefHeading___Toc81890298)

# 5.1 Project technical representative Monitoring responsibilities

**POLICY**: The Project Technical Representative (PTR) is the Financial
Assistance Officer's (FAO\'s) representative for monitoring the
activities of the recipient, and providing the FAO with advice about
whether the recipient is adhering to the requirements of the award. The
PTR is responsible for monitoring the award in accordance with the
principles outlined in this Part, and for assisting with closeout of the
award as described in Part 7.

**PROCEDURE:** The PTR must keep the FAO informed of project status.
This may be accomplished by using electronic BPA form F-4620.02, Project
Technical Representative's Status Report, or other written means.

# 

# 5.2 MONITORING TECHNICAL ACTIVITIES

## 5.2.1 General

> **POLICY:**

\(a\) The PTR\'s primary responsibility is to monitor the technical
activities of the recipient and ensure that the recipient performs in
accordance with the terms and conditions of the award without unduly
interfering with the recipient\'s activities.

\(b\) BPA should conduct site visits as warranted by project needs to
(1) review project accomplishments and management control systems, and
(2) provide technical assistance as needed.

\(c\) The PTR shall maintain adequate documentation of project
activities in an administration file and report to the FAO in accordance
with the procedure in 5.2.6.

\(d\) The PTR may conduct post-award technical orientation meetings with
the recipient. These meetings provide the PTR and the recipient an
opportunity to establish a working relationship, understand project
goals and expectations, and clarify award requirements. If the FAO is
not in attendance at the meeting, the PTR must submit a written report
of the proceedings to the FAO.

## 5.2.2 BPA-Furnished Support

**PROCEDURE:** The PTR tracks completion of BPA\'s obligations to the
recipient. The award will identify any BPA-furnished property or other
support. The PTR shall identify the actions BPA must take to furnish the
property or other support to the recipient as soon as the award is made.
BPA-furnished property will be identified in clause 4-24, Personal
Property Management, or 4-25, Personal Property Management. -- States,
Local Governments and Tribes.

## 5.2.3 Recipient Progress Reports

**PROCEDURE:** The recipient\'s progress and performance is assessed by
review of recipient progress reports. The PTR should:

\(a\) Confirm that progress reports are received as scheduled in the
award. If a report is not received as scheduled, the PTR should
determine why the reports late, and when it will be delivered.

\(b\) Review the report so that performance issues can be addressed. The
PTR shouId request clarification of a vague or incomplete report, and
inform the FAO of status.

## 5.2.4 Verify What the Recipient is Doing

**PROCEDURE:** The PTR should verify the activites described in the
progress report. The methods used for verification depend on the amount
and complexity of the award. The PTR may also inspect work and
activities described in the award. The PTR should minimize intrusion
into the recipient\'s activities.

## 5.2.5 Document Contacts With Recipient

**PROCEDURE:** The PTR should maintain records of contacts with the
recipient including significant phone conversations, personal visits and
correspondence.

## 5.2.6 PTR Status Reporting

**PROCEDURE:**

\(a\) The PTR should identify inadequacies and schedule changes using
project reports, activity verification and other information gathered in
connection with the award. The PTR should discuss any BPA concerns with
the recipient, and determine how the recipient will address them. The
PTR should regularly provide the FAO with a project update.

\(b\) Routine Reporting: PTR\'s should occasionally report to the FAO
that award activities are being performed as anticipated in the award.
PTR's should also send a status report to the FAO shortly after a
recipient\'s progress report is received.

\(c\) Non-routine Reporting: The PTR should inform the FAO whenever
exceptional events occur. For example, if the recipient consistently
late with reports on the project and the explanation for the delay is
inadequate, the PTR should contact the FAO. Other examples are when
inadequate progress is observed; when the project is complete; and when
the final payment request has been received.

# 5.3 MONITORING FINANCIAL Activities

## 5.3.1 General

**POLICY:** PTRs monitor the recipient\'s financial status. The PTR
shall review and certify the recipient's request for reimbursement or
advance payment, evaluate financial reports and other documents, and
advise the FAO of any significant anticipated overrun or underrun of the
estimated cost.

**INFORMATION:** The payment method (advance or cost reimbursement),
required financial reports, and reporting periods are outlined in each
award. Copies of required financial reports and detailed instructions
are provided by the FAO when the award is made. PTRs should provide
assistance to the recipients in completing those forms if appropriate.

## 5.3.2 Advance Payments

**POLICY:** The PTR certifies that the advance payment requested is a
reasonable estimate of the amount needed for the time period covered and
is consistent with the project budget.

**PROCEDURE:**

\(a\) Form SF-270e, Request for Advance or Reimbursement, is submitted
to the PTR by the recipient to request advance funds. It should not be
submitted more frequently than monthly except by prior approval of the
FAO. If the form is submitted for longer periods (i.e., quarterly), the
estimated needs for each of the periods must be stated Advances are not
typically made for more than 30 days. Also, predetermined advance
amounts or percentages shall not normally be used. The original shall be
sent to Accounts Payable, with copies retained by the PTR and FAO. No
other forms are needed to request an advance.

+------------+---------------+------------------------+---------+-----+
| REQUESTING |               |                        |         |     |
| AN ADVANCE |               |                        |         |     |
| OF FUNDS   |               |                        |         |     |
+------------+---------------+------------------------+---------+-----+
| FORM       | TIMING        | Recipient submits      | A       | FAO |
| REQUIRED   | (Unless       | original and two       | ccounts |     |
|            | otherwise     | copies to PTR, who     | Payable |     |
|            | specified in  | reviews, authorizes,   |         |     |
|            | the award)    | and forwards the       |         |     |
|            |               | original to Accounts   |         |     |
|            |               | Payable, retains one   |         |     |
|            |               | copy and forwards the  |         |     |
|            |               | other copy to the FAO. |         |     |
+------------+---------------+------------------------+---------+-----+
| SF-270e    | -Monthly      | Request advance funds. | O       | C   |
|            |               |                        | RIGINAL | OPY |
|            | -Quarterly    |                        |         |     |
|            |               |                        | R       |     |
|            | -Single       |                        | equired |     |
|            | Payment       |                        | for     |     |
|            |               |                        | payment |     |
+------------+---------------+------------------------+---------+-----+

\(b\) The PTR should review the SF-270e, by comparing outlays with the
approved budget, with previous outlays, and with the progress report,
including review of the drawdown rate and a check for excess funds on
hand. If acceptable, the PTR will approve payment, forward the original
to Accounts Payable, keep one copy, and forward one copy to the FAO.

\(c\) The PTR should resolve any questions about the request with the
recipient. If the PTR is unable to resolve the issue, the issue should
be referred to the FAO for resolution.

## 5.3.3 Reimbursement of Costs

POLICY: The PTR certifies that the costs claimed are reasonable for
project accomplishments to date. The PTR is not responsible for auditing
the request to assure the cost principles have been closely followed.

**PROCEDURE:**

\(a\) Form SF 270e, Request for Advance or Reimbursement, is used to
request reimbursement for expenses. Requests should not be submitted
more frequently than monthly. The PTR should review the cost
reimbursement requests using the following steps:

> \(1\) Review form SF-270e is to compare expenditures with the approved
> budget, with previous BPA outlays, and with the progress report,
> including review of the drawdown rate. The PTR should understand any
> charges and compare the actual expenditures against the award
> document, or the recipient's application or budget.
>
> \(2\) The PTR will approve reasonable requests for payments within 10
> days of submission, forward the original to Accounts Payable, keep one
> copy, and forward the other copy to the FAO.
>
> \(3\) If the information submitted by the recipient is inadequate, or
> the costs appear unreasonable or not allocable (or both), the PTR
> should attempt to resolve these concerns with the recipient. If the
> PTR is unsuccessful the FAO should be contacted to resolve the
> dispute. The FAO may authorize partial payment of those costs not in
> question. If the questioned costs are later determined to be
> allowable, they may then be paid. To authorize a partial payment of
> these costs, the PTR should send a memorandum authorizing the payment
> of the specific costs with a copy of the originally-submitted request
> for payment to Accounts Payable.

+------------+---------------+------------------------+---------+-----+
| REQUESTING |               |                        |         |     |
| A          |               |                        |         |     |
| REI        |               |                        |         |     |
| MBURSEMENT |               |                        |         |     |
| OF COSTS   |               |                        |         |     |
+------------+---------------+------------------------+---------+-----+
| FORMS      | TIMING        | Recipient submits      | A       | FAO |
| REQUIRED   | (Unless       | original and two       | ccounts |     |
|            | otherwise     | copies to PTR, who     | Payable |     |
|            | specified in  | reviews, authorizes,   |         |     |
|            | the award)    | and forwards the       |         |     |
|            |               | original to Accounts   |         |     |
|            |               | Payable, retains a     |         |     |
|            |               | copy, and forwards the |         |     |
|            |               | other copy to the FAO. |         |     |
+------------+---------------+------------------------+---------+-----+
| SF-270e    | -Monthly      | Request reimbursement  | O       | C   |
|            |               | of costs               | RIGINAL | OPY |
|            | -Quarterly    |                        |         |     |
|            |               |                        | R       |     |
|            | -Single       |                        | equired |     |
|            | Payment       |                        | for     |     |
|            |               |                        | payment |     |
+------------+---------------+------------------------+---------+-----+
| SF-269a    | -Quarterly    | Provide financial      | O       | C   |
|            |               | status of award effort | RIGINAL | OPY |
+------------+---------------+------------------------+---------+-----+

## 5.3.4 Review of Financial Status Reports

**INFORMATION:** Forms SF-269a, Financial Status Report is used by PTR's
to monitor elements of the project. A final Financial Status Report is
required before the last payment to the recipient can be made. Form
SF-272e, Federal Cash Transactions Report, is used to account for
Federal monies received when the recipient receives advance payments. It
is usually submitted whenever Form SF-269a, Financial Status Report is
submitted. The following steps should be taken to review advance
requests:

  ------------- --------------- ------------------------ ---------- ------
  REVIEWING AN                                                      
  AWARD\'S                                                          
  FINANCIAL                                                         
  STATUS                                                            

  FORMS         TIMING (Unless  Recipient submits        Accounts   FAO
  REQUIRED      otherwise       original and two copies  Payable    
                specified in    to PTR, who reviews,                
                the award)      authorizes, and forwards            
                                the original to Accounts            
                                Payable, retains a copy,            
                                and forwards the other              
                                copy to the FAO.                    

  SF-269a       -Quarterly      Provide financial status ORIGINAL   COPY
                                of award effort.                    

  SF-272e       -Same as        Account for money        ORIGINAL   COPY
                SF-269a         advanced.                Required   
                                                         for        
                                                         payment    
  ------------- --------------- ------------------------ ---------- ------

**POLICY:** The PTR reviews the Financial Status Report (FSR) to
determine if the recipient's financial status reasonably reflects
project progress, and an appropriate rate of expenditure.

**PROCEDURE:**

\(a\) Form SF 269a, FSR, is submitted to the PTR by the recipient as
prescribed in the award. If the FSR is not received as scheduled, the
PTR should follow-up to see that it is submitted. The following points
should be specifically reviewed on Form SF-269a:

> \(1\) Expenditures and/or rates should be compared to the original
> award budget. These figures also should have a direct relationship to
> the progress reported on goals and objectives by the recipient. If the
> progress report indicates a shortfall in goals and objectives while
> expenditure rates are at or above planned levels, a review with the
> recipient should be completed and the FAO should be informed.
>
> \(2\) Drawdown information will serve as a check on expenditures for
> the period. Drawdown and expenditure amounts should be close, although
> some differences may occur because of processing time and the
> reporting basis, i.e. cash or accrual.
>
> \(3\) For projects intended to generate program income, or cost
> sharing projects, the PTR's review should note whether actual income
> meets project expectations, whether the recipient is applying the
> income pursuant to the terms and conditions of the award, and whether
> the recipient is contributing the income to project costs.
>
> \(4\) If discrepancies or irregularities are apparent from the review
> and indicate potential project problems, then the PTR should use all
> available information to understand the situation, including
> additional information from the recipient, and conferring with
> internal resources such as General Counsel, Risk Management and
> Internal Audit.

\(b\) If the FSR is acceptable, the PTR will so indicate by writing
"Reviewed", signing, and dating the document above Block 13. The
original will be sent to Accounts Payable, with copies to the FAO.

\(c\) f the FSR is not acceptable because there appears to be an error
or the FSR is otherwise inadequate, the PTR should first attempt to
resolve the problem with the recipient as described in (c)(4) above. If
the PTR is unable to do so, they should seek direction from the FAO.

## 5.3.5 Anticipated Overruns

**INFORMATION:**

\(a\) When the recipient\'s incurred costs approach the ceiling amount
of the award, BPA personnel should not request or encourage the
recipient to continue work that exceeds the cost ceiling. Requesting or
encouraging additional work constitutes an action which exceeds the
PTR\'s authority. This may cause the agency to incur liability and the
PTR or responsible employee to be subject to discipline and personal
liability. Moreover the action may require ratification by a warranted
FAO or the Head of Contracting Activity.

\(b\) If total expenditures are anticipated to exceed the award amount,
BPA must determine whether to seek funds to continue the award effort,
terminate the award or other appropriate action.

\(c\) If additional funds are needed, early knowledge of the recipient's
incurred costs and the potential cost overrun is essential to minimize
impact on other projects and avoid a lapse in the recipient\'s
obligation.

**POLICY:** The PTR shall coordinate actions with the program office and
the FAO to determine what action BPA will take. If the program office
decides that additional funds will be made available, the FAO is
responsible for informing the recipient and modifying the award to
increase funds.

## 5.3.6 Disallowing Costs

**POLICY:** If the PTR determines that some costs are unreasonable and
should not be reimbursed the issue should be referred to the FAO for
resolution.The FAO will disallow those costs that are unreasonable or
not allocable (or both). The FAO may consult with Legal counsel and Risk
Management if costs appearing unreasonable are significant.

## 5.3.7 Monitoring Program Income

**INFORMATION:** Program income represents gross income earned by the
recipient or subrecipient from the federally supported activities. See
4.7 for the alternatives available for the use of \"program income\".
The alternative to be used will be specified in the award document.

**PROCEDURE:** The PTR reviews program income to determine whether
projected earnings are in line with actual earnings. Program income will
be reported on form SF-269a, Financial Status Report (FSR).

# 5.4 PROPERTY MANAGEMENT

**PROCEDURE:** The PTR has the following responsibilities for the
property management aspects of a financial assistance award:

\(a\) Be aware of the recipient\'s plans to acquire personal and real
property, and of the BFAI property standards that apply to such
property;

\(b\) Review or verify the acquisition of property by the recipient;

\(c\) Insure that any BPA-owned property or other commitment by BPA in
the award is made available to the recipient on a timely basis;

\(d\) Monitor the use of BPA-owned and recipient-acquired property and
report any misuse or discrepancy that threatens the property or project
to the FAO;

\(e\) Monitor the inventory of BPA-furnished property, note any
discrepancies and inform the FAO; and

\(f\) Assist in final inventory and disposition of property during award
closeout procedure.

# 5.5 MODIFICATIONS

**POLICY:** Awards may be changed through a written modification by the
FAO whenever it is in the best interests of BPA to do so.

**PROCEDURE:**

\(a\) Except as stated in other regulations or in an award, recipients
or subrecipients shall obtain prior approval from the FAO whenever any
of the following changes are anticipated:

> \(1\) Changes in the scope or the objective of the project or program
> that will require a budget revision.

\(2\) Additional funding or deobligation is needed to complete the
project.

\(3\) Changes to the terms and conditions.

\(b\) After completion of negotiations concerning any of the above, the
FAO will execute a modification to document the revisions.

## 5.5.1 Budget Changes

**POLICY:** After award, recipients and subrecipients may transfer funds
between line items within the approved budget to meet unanticipated
requirements up to 10% of the approved award budget. If line item
transfers exceed 10% of the approved budget (or current year\'s budget,
as specified in clause 4-27, Budget Changes and Line Item Transfers),
advance approval of the FAO and the Project Manager when there is a
budget increase is required.

**PROCEDURE:** If costs are to be charged as direct costs, and they are
not in the approved budget, specific prior written approval must be
obtained from the FAO, the recipient, or the subrecipient, as
appropriate, before such costs are incurred by the recipient,
subrecipient, or cost-type contractor.

## 5.5.2 Requesting Approval for Changes

**PROCEDURE:** When a recipient wishes to make a budget revision which
requires prior approval by the FAO, the recipient should submit a
written request to the FAO, through the PTR, which includes the
following:

\(a\) The nature of and rationale for the revision;

\(b\) The proposed revised budget prepared in the same format as the
original budget at award; and

\(c\) All pertinent information and supporting documentation needed to
review the proposed revision.

## 5.5.3 Review and Approval of Request

**PROCEDURE:** The PTR should review any budget revision request to
consider the possible impact of the change on the original purposes of
the project. The FAO is responsible for responding to recipient requests
for prior approval of budget revisions. Neither the PTR or the Project
Manager is authorized to approve or disapprove a budget revision except
as described in this Part.

**POLICY:** Retroactive budget approvals that do not exceed the award
amount, unless otherwise prohibited, may be provided at the discretion
of the FAO. Requests for retroactive approval shall be granted only if
extenuating circumstances justify such an approval and/or an approval
would have been made if the budget revision request had been submitted
in a timely manner.

## 5.5.4 Subrecipient Awards

**INFORMATION:** Recipients are responsible for executing and
administering all subrecipient awards to insure consistency with the
prime award scope and terms and conditions. If a subrecipient proposes a
revision that would result in a change to the recipients approved budget
or project. The recipient shall obtain BPA approval before authorizing
such a revision.

# 5.6 Extending the effective period of awards

**POLICY:** Awards may be extended beyond the planned expiration date
through a modification establishing a new effective period.

**PROCEDURE:**

\(a\) All extensions will require a request from the recipient. If
additional funding is required, the request shall contain a detailed
plan for conduct of the project and a detailed budget.

\(b\) The BES electronically generated award form will be used to
document continuation, and revision actions.

# 5.7 POST-EXPIRATION COSTS

**PROCEDURE:** Unless an effective period is extended, costs incurred
after the expiration of a budget period are not allowable. The FAO may
give the recipient express written consent for the incurrence of
anticipated closeout costs. This may be accomplished by extending the
effective period and setting a budget ceiling on the amount of costs to
be incurred during the extended period.

# 5.8 REMEDIAL ACTIONS

## 5.8.1 Determining if Remedial Action is Needed

**INFORMATION:** The PTR may discover that the recipient has failed to
meet certain deadlines or planned milestones. The PTR should confer with
the recipient to determine the reasons for these lapses and report to
the FAO for direction.

## 5.8.2 Initial Action When Award Requirements Are Not Being Met

**PROCEDURE:** When a PTR discovers the existence and cause of a
discrepancy or delay the PTR will inform the FAO. The FAO in conjunction
with the PTR, Project Manager, Legal Counsel and Risk Managerment and
Internal Audit, as appropriate, will assess alternatives, contact the
recipient and, if possible, attempt to informally resolve the problem.

### 5.8.2.1 Recipient Agrees With PTR

**PROCEDURE:** When the recipient agrees that the award requirements are
not being met, BPA or the recipient may propose a resolution. The
proposal will be negotiated and, if changes are agreed upon, the changes
will be documented in writing. However, if the parties are unable to
agree upon a resolution or, if the FAO determines that the problem is so
severe and the required corrective action so expensive that further
performance is impractical, the award should be terminated.

### 5.8.2.2 Recipient Disagrees With PTR

**PROCEDURE:**

\(a\) If the recipient disagrees with the determination of the PTR, that
award requirements are not being met, the PTR should confirm the basis
of the recipient\'s position and notify the FAO for resolution. The FAO
may direct the PTR to advise the recipient in writing of the need to
take corrective action to meet the requirements of the award.

\(b\) A dispute by a recipient does not produce a claim. The decision of
the FAO is final. However, a decision to terminate an award may be
appealed to the BPA HCA for a final determination.

(c) 

[]{#__RefHeading___Toc81890298 .anchor}5.8.2.3 Noncompliance

**PROCEDURE:** Whenever the PTR determines that a recipient has not
complied with the requirements of the award, the PTR shall provide to
the FAO a memorandum setting forth the basis for the determination of
noncompliance. The FAO will determine the action to be taken including
award modification to assure compliance with project goals or
termination.