Compliance

Review Guide

Procedural Processes for Conducting 

Pre-award Compliance Reviews and 

Post-award Compliance Reviews

Office of Small Business and Civil Rights
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Compliance

Review Guide

Procedural Processes for Conducting 

Pre-award Compliance Reviews and 

Post-award Compliance Reviews

Manuscript Completed: December 2015

Date Published: December 2015

Office of Small Business and Civil Rights

NUREG-2186 

Page | iii

CONTENTS

1. INTRODUCTION ...................................................................................................................................... 1

1.1 Overview....................................................................................................................................... 1

1.2 Background – Excerpt from DOJ’s Title VI Legal Manual ............................................................ 1

1.2(1) Federal Funding Agency Methods to Evaluate Compliance ......................................................... 1

A. Pre-Award Procedures ..................................................................................................... 1

1. Assurances of Compliance ................................................................................... 1

2. Deferral of the Decision Whether to Grant Assistance.......................................... 2

3. Pre-Award Authority of Recipients vis-à-vis Subrecipients.................................... 2 

4. Data Collection ..................................................................................................... 3

5. Recommendations Concerning Pre-Award Reviews ........................................... 3

B. Post-Award Compliance Reviews .................................................................................... 3

1. Selection of Targets and Scope of Compliance Review........................................ 3

2. NRC’S PRE-AWARD COMPLIANCE REVIEW PROGRAM ................................................................... 5

2.1 Pre-Award Compliance Review Process ...................................................................................... 5 

A. Pre-Award Procedures...................................................................................................... 5

1. Step 1 — OCCP Administrative Assistant or Designated Staff.............................. 5

2. Step 2 — Civil Rights Specialist or Designated Staff ............................................ 5

3. Step 3 — Program Manager ................................................................................. 6

4. Step 4 — OCCP Administrative Assistant or Designated Staff Continuation ........ 7

3. NRC’S POST-AWARD COMPLIANCE PROGRAM ................................................................................ 9

3.1 Post-Award Compliance Review Process ........................................................................................9 

A. Post-Award Procedures .................................................................................................... 9

1. Step 1 — Desk Audit ............................................................................................. 9

2. Step 2 — Record Keeping..................................................................................... 9

3. Step 3 — Group Meeting Discussion .................................................................... 9

4. Step 4 — Ranking Meeting ................................................................................... 9

5. Step 5 — Communicating with Recipients ............................................................ 9

6. Step 6 — On-Site Audits ....................................................................................... 9

7. Step 7 — Exit Interview....................................................................................... 10

8. Step 8 — Drafting Summary of Findings............................................................. 10

9. Step 9 — Monitoring Recipient Compliance with Recommendations ................. 10

10. Step 10 — Annotating Case File ......................................................................... 10

APPENDIX A – COVER LETTER TO INITIATE PRE-AWARD COMPLIANCE REVIEW.......... 13

APPENDIX B – NRC FORM 781 — PARTS A, B, AND C.......................................................... 17

APPENDIX C – FORM 424B — ASSURANCES – NON-CONSTRUCTION PROGRAMS ....... 21
iv | Page

APPENDIX D – SUMMARY REPORT OF COMPLIANCE REVIEW.......................................... 25

APPENDIX E – NOTICE TO AMD THAT APPLICANT(S) ARE IN COMPLIANCE .................... 33

APPENDIX F – NOTICE TO AMD THAT APPLICANT(S) HAVE BEEN PLACED IN 

 PERIODIC STATUS.......................................................................................... 37

APPENDIX G – NOTICE TO AMD OF CONTINUATION OF PERIODIC STATUS .................... 41

APPENDIX H – NOTICE TO AMD OF REMOVAL FROM PERIODIC STATUS......................... 45

APPENDIX I – CRITERIA/DATA COLLECTION FORM USED TO TARGET RECIPIENTS 

 FOR ONSITE AUDIT ........................................................................................ 49

APPENDIX J – POST-AWARD COMPLIANCE ASSESSMENT—REQUEST TO 

 CONDUCT ONSITE VISIT................................................................................ 53

APPENDIX K – POST-AWARD COMPLIANCE ASSESSMENT—REQUEST FOR 

 ADDITIONAL INFORMATION .......................................................................... 57

APPENDIX L – POST-AWARD COMPLIANCE ASSESSMENT—DETERMINATION 

 LETTER OF COMPLIANCE WITH REGULATIONS ........................................ 61
Procedural Process for Conducting Pre-Award

Compliance Reviews and Post-Award Compliance Reviews

Page | 1

1. INTRODUCTION

1.1 Overview

The U.S. Nuclear Regulatory Commission (NRC) is responsible for providing regulatory oversight of coordinating 

compliance with and enforcing Title VI of the Civil Rights Act of 1964, including the provisions related to 

limited English proficiency; Title IX of the Educational Amendments Act of 1972; Sections 504 and 508 of the 

Rehabilitation Act of 1973, as amended; the Age Discrimination Act of 1975, as amended; and Title IV of the 

Atomic Energy Act, as amended. These acts are adopted and incorporated in NRC regulations under Title 10 of 

the Code of Federal Regulations (10 CFR) Part 4, “Nondiscrimination in Federally Assisted Programs or Activities 

Receiving Federal Financial Assistance from the Commission,” and 10 CFR Part 5, “Nondiscrimination on the 

Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance.”

The Office of Small Business and Civil Rights (SBCR) administers NRC civil rights compliance programs. SBCR 

is required to establish and maintain effective pre- and post-award compliance review programs to ensure that 

award recipients comply with Federal mandates and nondiscrimination laws.

The NRC uses several mechanisms (pre- and post-award compliance reviews, and investigations) to ensure 

equal opportunity and fair practices in the programs and activities of NRC award recipients. This reference guide 

provides information on the Outreach and Compliance Coordination Program’s (OCCP’s) pre- and post-award 

compliance processes.

1.2 Background – Excerpt from DOJ’s Title VI Legal Manual

1.2(1) Federal Funding Agency Methods to Evaluate Compliance

The Federal agency providing the financial assistance is primarily responsible for enforcing Title VI as it applies 

to its recipients. Agencies have several mechanisms available to evaluate whether recipients are in compliance 

with Title VI, and additional means to enforce or obtain compliance should a recipient’s practices be found lacking. 

Evaluation mechanisms, discussed below, include pre-award reviews, post-award compliance reviews, and 

investigations of complaints. 

A. Pre-Award Procedures 

Agencies should endeavor to ensure that awards of Federal financial assistance are only granted 

to entities that adhere to the substantive antidiscrimination mandates of Title VI and other 

nondiscrimination laws.

1. Assurances of Compliance 

The Title VI Coordination Regulations, (as well as the Section 504 coordinating regulation), require 

that agencies obtain assurances of compliance from prospective recipients. 28 C.F.R. §§ 41.5(a)

(2), 42.407(b). Regulations requiring applicants to execute an assurance of compliance as a 

condition for receiving assistance are valid. Grove City, 465 U.S. at 574–575 (Title IX assurances); 

Gardner v. Alabama, 385 F.2d 804 (5th Cir. 1967), cert. denied, 389 U.S. 1046 (1968) (Title VI 

assurances). If an applicant refuses to sign a required assurance, the agency may deny assistance 

only after providing notice of the noncompliance, an opportunity for a hearing, and other statutory 

procedures. 42 U.S.C. § 2000d-1;28 C.F.R. § 50.3 II.A.1. However, the agency need not prove 

actual discrimination at the administrative hearing, but only that the applicant refused to sign an 

assurance of compliance with Title VI (or similar nondiscrimination laws). Grove City, 465 U.S. 

at 575. Assurances serve two important purposes: they remind prospective recipients of their 

nondiscrimination obligations, and they provide a basis for the Federal government to sue to enforce 
2 | Page

compliance with these statutes. See United States v. Marion County Sch. Dist., 625 F.2d 607, 609, 

612–13 (5th Cir.),reh’g denied, 629 F.2d 1350 (5th Cir. 1980), cert. denied, 451 U.S. 910 (1981).

2. Deferral of the Decision Whether to Grant Assistance— The “Guidelines for the Enforcement of 

Title VI, Civil Rights Act of 1964,” (the “Title VI Guidelines”) specifically state that agencies may defer 

assistance decisions: “In some instances it is legally permissible temporarily to defer action on an 

application for assistance, pending initiation and completion of [statutory remedial] procedures— 

including attempts to secure voluntary compliance with Title VI.” 28 C.F.R. § 50.3 I.A. Thus, deferral 

may occur while negotiations are ongoing to special condition the award, during the pendency of a 

lawsuit to obtain relief, or during proceedings aimed at refusing to grant the requested assistance.

This interpretation is a reasonable, and even necessary, application of the statutory remedial scheme. 

The congressional authorization to obtain relief pre-award would be sharply reduced, if not rendered 

a near nullity, if agencies could not postpone the assistance decision while spending the time needed 

to conduct a full and fair investigation and while seeking appropriate relief. Furthermore, the Attorney 

General’s administrative interpretation is entitled to deference. See, e.g., Chevron U.S.A. v. Natural 

Resources Defense Council, Inc., 467 U.S. 837, 842–45 (1984).

The Title VI Guidelines recommend that agencies adopt a flexible case-by-case approach in assessing 

when deferral is appropriate, and consider the nature of the potential noncompliance problem. Where 

an assistance application is inadequate on its face, such as when the applicant has failed to provide 

an assurance or other material required by the agency, “the agency head should defer action on the 

application pending prompt initiation and completion of [statutory remedial] procedures.” 28 C.F.R. § 

50.3 II.A.1 (emphasis added). Where the application is adequate on its face but there are “reasonable 

grounds” for believing that the applicant is not complying with Title VI, “the agency head may defer 

action on the application pending prompt initiation and completion of [statutory remedial] procedures.” 

Id. II.A.2 (emphasis added).

When action on an assistance application is deferred, remedial efforts “should be conducted without 

delay and completed as soon as possible.” Id. I.A. Agencies should also be cognizant of the time 

involved in a deferral to ensure that a deferral does not become “tantamount to a final refusal to grant 

assistance.” Id. II.C. The agency should not completely rule out deferrals where time is of the essence 

in granting the assistance, but should consider special measures that may be taken to seek expedited 

relief (e.g., by referring the matter to the Department of Justice to file suit for interim injunctive relief).

3. Pre-Award Authority of Recipients vis-à-vis Subrecipients

The Title VI Guidelines provide that the “same [pre-award] rules and procedures would apply” 

where a Federal assistance recipient is granted discretionary authority to dispense the assistance to 

subrecipients. Id. III:

[T]he Federal Agency should instruct the approving agency— typically a State agency—to defer 

approval or refuse to grant funds, in individual cases in which such action would be taken by the original 

granting agency itself.... Provision should be made for appropriate notice of such action to the Federal 

agency which retains responsibility for compliance with [Title VI compliance] procedures. Id.

Thus, the Title VI Guidelines support Federal agencies requiring that recipients/subgrantors obtain 

assurances of compliance from subrecipients. When the recipient receives information pre-award that 

indicates noncompliance by an applicant for a subgrant, recipients may defer making the grant decision, 

may seek a voluntary resolution and, if no settlement is reached, (after complying with statutory 

procedural requirements), may refuse to award assistance.
Page | 3

4. Data Collection

Section 42.406(d) of the Coordination Regulations lists the types of data that should be submitted to 

and reviewed by Federal agencies prior to granting funds. In addition to submitting an assurance that 

it will compile and maintain records as required, an applicant should provide: (1) notice of all lawsuits 

(and, for recipients, complaints) filed against it; (2) a description of assistance applications that it has 

pending in other agencies and of other Federal assistance being provided; (3) a description of any civil 

rights compliance reviews of the applicant during the preceding two years; and (4) a statement as to 

whether the applicant has been found in noncompliance with any relevant civil rights requirements. Id.

The Coordination Regulations require that agencies “shall make [a] written determination as to whether 

the applicant is in compliance with Title VI.” 28 C.F.R. § 42.407(b). Where a determination cannot be 

made from the submitted data, the agency shall require the submission of additional information and 

take other steps necessary for making a compliance determination, which could include communicating 

with local government officials or community organizations and/or conducting field reviews. Id.

5. Recommendations Concerning Pre-Award Reviews

It is recommended that agencies implement an internal screening process whereby agency officials 

are notified of potential assistance grants and are provided the opportunity to raise a “red flag” or 

concern about the potential grant recipient. If limited resources are a problem, agencies should develop 

a system to target a significant proportion of assistance applications. As part of the Department of 

Justice’s oversight and coordinating function, each agency should submit to the Department, as part of 

its annual implementation plan, any targeting procedures that are adopted.

B. Post-Award Compliance Reviews

Federal agencies are required to maintain an effective program of post-award compliance reviews. 

Federal agency Title VI regulations reiterate this requirement. Compliance reviews can be large and 

complex, or more limited in scope.

1. Selection of Targets and Scope of Compliance Review

Federal agencies have broad discretion in determining which recipients and subrecipients to target for 

compliance reviews. However, this discretion is not unfettered. In United States v. Harris Methodist 

Fort Worth, 970 F.2d 94 (5th Cir. 1992), the Fifth Circuit found that a Title VI compliance review involves

an administrative search and, therefore, Fourth Amendment requirements for “reasonableness” of 

a search are applicable. The Court considered three factors: (1) whether the proposed search is 

authorized by statute; (2) whether the proposed search is properly limited in scope; and (3) how the 

administrative agency designated the target of the search. Id. at 101; United States v. New Orleans 

Pub. Serv. Inc., 723 F.2d 422 (5th Cir.) reh’g en banc denied, 734 F.2d 226 (5th Cir. 1984) [hereinafter 

NOPSI III] (E.O. 11246 compliance review unreasonable) (citing United States v. Mississippi Power 

& Light Co., 638 F.2d 899 (5th Cir. 1981)); and First Ala. Bank of Montgomery, N.A., v. Donovan, 692 

F.2d 714, 721 (11th Cir. 1982) (Exec. Order No. 11246 compliance review reasonable); see Marshall v. 

Barlow’s Inc., 436 U.S. 307 (1978).

The Harris Methodist Court suggested that selection of a target for a compliance review will be 

reasonable if it is based either on (1) specific evidence of an existing violation, (2) a showing that 

“reasonable legislative or administrative standards for conducting an...inspection are satisfied with 

respect to a particular [establishment],” or (3) a showing that the search is “pursuant to an administrative 

plan containing specific neutral criteria.” Harris Methodist, 970 F.2d at 101 (internal citations omitted); 

NOPSI III, 723 F.2d at 425.
4 | Page

In Harris Methodist, the court rejected the Department of Health and Human Services’ (HHS’) 

attempts to gain access to records, including a vast array of records associated with confidential, 

physician peer review evaluations, as part of a compliance review of the hospital. The court held that 

signing an assurance gives consent “only to searches that comport with constitutional standards of 

reasonableness.” 970 F.2d at 100. Where the proposed compliance review was not subjected to 

management review and not based upon consideration of a management plan or objective criteria, 

the court of appeals agreed that the HHS office acted “arbitrarily and without an administrative plan 

containing neutral criteria.” Id. at 103.

Thus, agencies are cautioned that they should not select targets randomly for compliance reviews 

but, rather, they should base their decisions on neutral criteria or evidence of a violation. A credible 

complaint can serve as specific evidence suggesting a violation that could trigger a compliance review.

In developing targets for compliance reviews, agencies may wish to take into consideration the 

following:

• Issues targeted in the agency’s strategic plan, if any;

• Issues frequently identified as problems faced by program beneficiaries;

• Geographical areas the agency wishes to target because of the many known problem 

beneficiaries are experiencing or because the agency has not had a “presence” there for 

some time;

• Issues raised in a complaint or identified during a complaint investigation 

that could not be covered within the scope of the complaint investigation;

• Problems identified to the agency by community organizations or 

advocacy groups that cite actual incidents to support their concerns;

• Problems identified to the agency by its block grant recipients; and

• Problems identified to the agency by other Federal, State, or local civil 

rights agencies.

Apart from complying with the standards outlined above, it is recommended that a decision to 

conduct a compliance review be set forth in writing and approved by senior civil rights management. 

An agency may be required to show that it has selected its targets for compliance reviews in 

an objective, reasonable manner. A contemporaneous, written record that reflects the factors 

considered will aid in refuting allegations of bias or improper targeting of a recipient. See NOPSI III, 

723 F.2d at 428. The memorandum should identify any regulations or internal guidance that set forth 

criteria for selection of targets for compliance reviews, and explain how such criteria are met.
Page | 5

2. NRC’s PRE-AWARD COMPLIANCE REVIEW PROGRAM

2.1 Pre-Award Compliance Review Process

A. Pre-Award Procedures

Before making an award, the NRC Acquisition Management Division (AMD), or office designated by 

AMD, must request in writing that OCCP conduct a pre-award compliance review. The request must be 

accompanied by (1) an application for funding (all related documents) and (2) a request for procurement 

action. Requests to conduct pre-award compliance reviews must be submitted to 

OCCPrograms.Resource@nrc.gov. At minimum, OCCP must perform the following four steps to conduct a

pre-award compliance review:

1. Step 1 — OCCP Administrative Assistant or Designated Staff:

a) Log in (date stamp) the request to conduct a compliance review and application documents 

received from AMD or the designated NRC office.

b) Assign an SBCR Pre-Award Compliance Program case number (i.e., office, year, month number 

(reflecting the order in which the case was received), and abbreviation for the submitting office) 

(e.g., SBCR 20XX-01-21).

c) Enter case information in the OCCP automated tracking system.

d) Set up the case file (electronically and hard case files with labels).

e) Assign the case file to OCCP staff, based on instructions from the program manager (PM).

2. Step 2 — Civil Rights Specialist or Designated Staff:

a) Review the application and documents (proposal submission, other required documents, and 

standard forms) forwarded by AMD and the designated NRC office. 

b) Set up a compliance review plan for handling the case and carrying out associated tasks. 

Calculate the agency’s mandated completion time (20 business days) and the internal 

completion date set by the PM to ensure both target dates are met. Obtain approval of the 

completion date from the PM or designee.

c) Establish initial contact with a representative of the potential awardee to determine the 

appropriate applicant/recipient designee for purpose of conducting the pre- award compliance 

review.

d) Immediately send out standard OCCP information, customized based on the case file. If 

possible, on the day of receipt of the request/case from AMD. Include in the information a notice 

of request to conduct a pre-award compliance review; SBCR’s purpose and authority; and 

request for information/documentation contained in NRC Form 781, Parts A, B, and C, approved 

by the Office of Management and Budget-for information collection for SBCR compliance review. 

If the proper signature is not affixed to the information received from AMD or the designated 

NRC office, contact the appropriate individual to request information required to sufficiently 

conduct the pre-award Compliance Review.
6 | Page

e) Conduct an initial teleconference with the authorized official from institution on entity receiving 

the review. Explain the regulatory requirements, compliance obligations, compliance process, 

and information and documents requested. Make relevant inquiries, address applicant/

recipient questions, provide technical assistance, and establish a relationship for outreach 

purposes.

f) Follow up with the representative, as warranted.

g) Verify that the signature of a representative authorized to ensure execution of the recipients’ 

equal employment program(s) is affixed to NRC Assurance Form 424B.

h) Research and apply specific laws and applicable legal theories to applicant/recipient 

information and documentation, and make other factual findings sufficient to determine the 

applicant’s/recipient’s compliance with Federal nondiscrimination laws and mandates and 

NRC regulatory requirements.

i) Draft the compliance summary report using the designated OCCP template and submit the 

report to the PM for review and concurrence.

j) Track and maintain all aspects of case processing; notate the file to document timely completion, 

receipt of information/documentation, and production of legally sufficient and quality reviews.

k) Keep the PM informed of progress and all concerns or problems encountered during the preaward compliance review process.

3. Step 3 — Program Manager:

a) Meet routinely with OCCP staff (in a group and individually) to discuss each staff member’s 

case fi observe progress, and provide constructive (positive/ negative) feedback to ensure 

quality outputs.

b) Conduct an internal review of OCCP case file and staff file once the staff completes the 

compliance reviews.

c) Determine the sufficiency of information/documentation contained in the case file and summary 

report.

d) Provide guidance and instructions to the staff and make comments, changes, and other 

recommendations.

e) Approve or reject the compliance review.

f) Issue a notice of determination to AMD indicating whether the applicant/recipient has been 

determined to be in compliance, placed in a conditional compliance status for a designated 

period, preferably sixty (60) days, in order to determine their compliance with civil rights 

regulations and mandates, or found to be in noncompliance with applicable legal authorities.
Page | 7

4. Step 4 — OCCP Administrative Assistant or Designated Staff Contination:

a) Enter the applicant’s/recipient’s compliance status in the OCCP automated tracking system.

b) Close out the case file under the Pre-Award Compliance Program.

c) Open the case file under the Post-Award Compliance Program.

d) Notate all administrative actions taken, including their dates.

e) Assign the post-award case file to OCCP staff based on PM direction.

f) Maintain a case log of pre-award compliance review activities (e.g., information on 

compliance review requests received, compliance reviews conducted, determination of 

findings, and final disposition).

Page | 9

3. NRC’s POST-AWARD COMPLIANCE REVIEW PROGRAM

3.1 Post-Award Compliance Review Process

A. Post-Award Procedures

Federal agencies must maintain an effective program of post-award compliance reviews. Federal 

agency Title VI regulations reiterate this requirement. Compliance reviews can be large and complex, or 

more limited in scope.

As stated in the Background section above—Federal agencies granting Federal financial assistance 

are required to “establish and maintain an effective program of post-approval compliance reviews” 

of recipients to ensure that the recipients are complying with the requirements of Title VI. 28 C.F.R. 

§ 42.407(a). Related to the reviews themselves, recipients should be required to submit periodic 

compliance reports to the agencies and, where appropriate, conduct field reviews of a representative 

number of major recipients. Finally, the Coordination Regulations recommend that agencies consider 

incorporating a Title VI component into general program reviews and audits. 28 C.F.R. § 42.407(c) (1).

Results of post-approval reviews by the Federal agencies should be in writing and include specific 

findings of fact and recommendations. The determination by the Federal agency of the recipient’s 

compliance status shall be made as promptly as possible. 28 C.F.R. § 42.407(c).

At minimum, OCCP staff must take the following 10 steps to conduct a post-award compliance review:

1. Step 1 — Desk Audit:

Conduct a desk audit of all recipients, including an analytical review of the following information/ 

documentation.

2. Step 2 — Record Keeping

Record desk audit file on the Criteria/Data Collection Form.

3. Step 3 — Group Discussion Meeting

Participate in group meetings to determine recipients targeted for onsite audits, those required to 

submit additional report information, and those with no identifiable concerns. Present, verify, and 

support staff findings. Make the staff recommendation or finding part of the file.

4. Step 4 — Ranking Meeting

Participate in OCCP meetings to rank recipients targeted for onsite audits, those from whom 

additional information is needed to ensure compliance status, and those that are in full compliance.

5. Step 5 — Communicating with Recipients

Send the appropriate communications (using OCCP templates) to the designated recipients 

(categories A, B, and C). 

a) Use Template A for Category A: In compliance.

b) Use Template B for Category B: Caution—issues raised; clarify or obtain information needed 

to make a determination.

c) Use Template C for Category C: Issues of concern or “red flags”; onsite audit required.

6. Step 6 — On-Site Audits

Conduct onsite audits of a targeted sampling of those in category C (not to exceed 10 percent of 

potential NRC award recipients for whom there are issues of concern or “red flags. The onsite 

audit encompasses a broad review of the recipient’s programs and practices to determine actual 

compliance with Federal mandates and regulations.
10 | Page

7. Step 7— Exit Interview

Conduct an exit interview upon completion of the onsite visit and discuss findings with recipient 

representatives.

8. Step 8 — Drafting Summary of Findings

Prepare a written draft outlining the findings of the onsite audit, including verification of information/

documents and recommendations for achieving compliance. Submit

this draft to the PM for review and concurrence. Send the final notification through SBCR’s chain 

of command for concurrence (i.e., PM, Deputy Director, or Director). Use the authorized template to 

prepare the draft correspondence for the administrative assistant to send upon approval. Document 

and file the final report.

9. Step 9 — Monitoring Recipient Compliance with Recommendations

Follow up with recipients to ensure their compliance with the recommendations made by OCCP. 

Document follow-up contacts discussing activities.

10. Step 10 — Annotating Case File

Make notations to the file of all efforts taken and technical assistance provided to the recipient to 

ensure voluntary compliance with applicable Federal laws and mandates.

ALL EFFORTS/ACTIONS MUST BE NOTATED IN THE APPROPRIATE FILE.
APPENDIX A – COVER LETTER TO INITIATE 

PRE-AWARD COMPLIANCE REVIEW

Page | 13

APPENDIX A – COVER LETTER TO INITIATE PRE-AWARD COMPLIANCE REVIEW

(Send Electronically)

My name is ________________. I am a __________________ for the Nuclear Regulatory 

Commission’s (NRC) Office of Small Business and Civil Rights (SBCR). This correspondence is 

being sent to you in order to initiate the conducting of a pre-award review. 

Prior to NRC’s Acquisition Management Division execution of procurement awards, SBCR 

is required to conduct a pre-award review. The pre-award review is mandated under NRC’s 

Procurement Financial Assistance Program, and applicable Civil Rights statutes and regulations. 

The review and issuance of findings must be conducted within 20 business days following receipt 

of the pre-award package from the Contracting Officer. Upon completion of the pre-award review, 

SBCR provides a written report of findings to the Acquisition Management Division for appropriate 

action.

SBCR has received a request from the Acquisition Management Division to conduct a pre-award 

review in connection with the University’s submission for funding of the project entitled, “Name of 

Project”. Your assistance is needed to expeditiously conduct the required review.

Please contact me at XXX-XXX-XXXX, in order that I can cover the information required in 

SBCR’s Forms PART A, B and C, address any questions or issues of concern, and ensure prompt 

receipt of the required information/documentation needed to complete this process. 

If your organization has recently undergone a pre-award review, during our initial conversation I 

will let you know which documents may be cross-filed. Notwithstanding, SBCR will need Parts A, 

B and C to be completed, and responses made with respect to this funding request.

As part of our process improvement initiative the forms can be completed online at 

http://www.nrc.gov/reading-rm/doc-collections/forms/nrc781.pdf. The 424B and other relevant 

information and documentation can be forwarded to me electronically at: 

OCCPrograms.resource@nrc.gov.

Thank you in advance for your cooperation.

Best Regards,

Name

Title

Outreach Coordination and Compliance Programs

Office of Small Business and Civil Rights

Phone: 301-415-4086

Fax: 301-415-5953

SAMPLE

APPENDIX B – NRC FORM 781— PARTS A, B, AND C

Page | 17

APPENDIX B – NRC FORM 781— PARTS A, B, AND C

SAMPLE
18 | Page

SAMPLE
APPENDIX C – FORM 424B—ASSURANCES – NON-CONSTRUCTION PROGRAMS

Page | 21

APPENDIX C – FORM 424B—ASSURANCES – NON-CONSTRUCTION PROGRAMS

SAMPLE
22 | Page

SAMPLE
APPENDIX D – SUMMARY REPORT OF COMPLIANCE REVIEW

Page | 25

APPENDIX D – SUMMARY REPORT OF COMPLIANCE REVIEW

SUMMARY REPORT OF COMPLIANCE REVIEW

 : Pre-Award Compliance Review

: Name of Entity

: AMD No. App. # XX-XXXX

: Originating Office No. Office-Year-Number

: SBCR Compliance No. Year-Month-Number 

 

AUTHORITY:

The Office of Small Business and Civil Rights (SBCR) administer the U.S. Nuclear Regulatory Commission’s 

(NRC) civil rights programs, including the conducting of pre and post award and periodic compliance reviews. 

SBCR is vested with the authority to conduct compliance reviews in accordance with NRC’s Procurement 

Financial Assistance Program, and applicable Civil Rights statutes and regulations. 

PRELIMINARY INFORMATION:

On Month-Day-Year, SBCR received a request from the Acquisition Management Division to conduct a preaward compliance review for, Name of Entity (hereinafter referred to as, the applicant). On Month-Day-Year, 

the applicant was given verbal notification of the pre-award compliance review process, guidance in completing 

document requests, and questions by the applicant were addressed by staff. The applicant was subsequently 

sent a letter, which reiterated the information provided during the verbal notification, date information/documents 

needed to be returned to SBCR in order to complete the review within the 20 day period allotted, and the 

required information/document submission requests (SBCR’s Compliance Forms Part A, B and C).

On Month-Day-Year, the applicant submitted its responses to SBCR. 

ANALYSIS OF INFORMATION/DATA COLLECTION:

Program/Contract Services: 

The applicant identified the manner in which services will be provided, and data/information necessary 

for determining whether individuals will be denied such services on the basis of prohibited discrimination. 

According to the applicant, the Entity’s Administrative Announcement No. 5 – Policy on Equal Opportunity 

states, “Our image and outstanding service are enhanced when our employment decisions and academic 

practices are fair. In the way, we acknowledge the worth and value of the individuals in the University 

community, and uphold Title VII of the Civil Rights Act and State General Law Chapter 151B. University policies 

reflect these non-discrimination and anti-harassment laws. Such as factors as race, color, religion, disability, 

age, gender, sexual orientation, ancestry, national origin, marital or veteran status and genetic information be 

considered factors in any academic or personnel decisions...” The policy can be reviewed at 

http://www.entity website.edu/equal/Equal Opportunity.

Based on the information provided, SBCR has determined that the applicant has policies in place prohibiting 

discrimination, and to address allegations of discriminatory practices.

Program/Contact Population Served: 

The applicant identified the geographic location(s) where the program/services will be provided. According to 

the applicant, the program activities/services will be provided in City, State and online (if applicable).

A review of the U.S. Census Bureau reveals that the potential LEP populations in close proximity to where the 

college and its alternate facilities are located are African American (X.X %), Hispanic (X.X %), Asian (X.X %), 

Native American (X.X %) and any other race identified (X.X %).

SAMPLE
26 | Page

Based on the information provided, SBCR has determined that the locations in which the applicant will provide 

services do not pose concerns of discrimination. 

Collection of EO Data:

Recipients are required to track and maintain EO data regarding the population eligible to be served and actual 

program participants (i.e., race, color, national origin, sex). The applicant identified how the recipient program 

collects EO data. According to the applicant, participants are requested to identify during the application 

process.” Additionally, the applicant stated, “EO data is tracked by the Entity name and reports prepared yearly. 

This information can be provided upon request.”

Based on the information submitted, SBCR has determined that the information/documentation provided 

satisfies this area of inquiry.

Limited English Proficiency: 

The applicant provided information/data regarding covered employment, including use or planned use of 

bilingual public-contact employees serving beneficiaries of the program where necessary to permit effective 

participation by beneficiaries unable to speak or understand English. According to the applicant, “The Institution 

offers the Centers for Learning and Academic Support Services (CLASS) to improve the quality of the student 

academic experience at Name of Entity. In addition, Advising, Computing Services, Tutoring Servings, StudyAbroad Program and Strategies for Success services are available. In addition the Institutions offer student 

assistance through their special populations/non-traditional studies office, and special need/disability services 

office”. The services can be reviewed on the website: http://www.Entity Website.edu/class.

Based on the applicant’s information and independent findings, SBCR has determined that the applicant has 

measures in place to provide meaningful access to potential LEP persons.

Facilities and/or Locations:

The applicant identified the location(s) of existing or proposed facilities connected with the program/

services, and related information adequate for determining whether the location has or will have the effect 

of unnecessarily denying access to any persons on the basis of prohibited discrimination. According to the 

applicant, “Services will be provided at the Name the location facility, on the Name of Entity Campus and 

will be used to teach the proposed courses. The building is accessible by handicapped persons and has 

an elevator. The institution’s Administrative Announcement No.7s – Policy on Equal Opportunity for Person 

with Disabilities. The policies can be located on http://www.Entity’s Website.edu/student-services/disability. 

Facilities are compliant and are accessible and feature adequate signage, ramps, parking and restroom 

facilities.” Additionally, the applicant states “The Institution implements a full ADA policy, is 504 compliant, and 

provides special needs and disability counseling”. 

Based on the information provided, SBCR has determined that the applicant’s response does not raise 

concerns regarding denial of access to individuals on the basis of prohibited discrimination. 

Organizational Membership:

The applicant identified the present or proposed membership, by race, color and national origin, in its planning 

or advisory body which is an integral part of the program/service provided. According to the applicant, “The 

current faculty members are Caucasian American citizens”. 

The information provided was not sufficient. The applicant was given a follow up call to request additional 

information, i.e. the number of members and respective gender(s). On Month-Day-Year, the applicant amended 

the Name of Entity’s response. The amended information is included in the applicant’s file.

Based on the information submitted and additional findings, SBCR has determined that amended submission is 

sufficient information/documentation to satisfy this area of inquiry.

SAMPLE
Page | 27

Changes in Location:

The applicant was requested to identify where relocation is involved, the requirements and steps used or 

proposed to guard against unnecessary impact on persons in the protected classes identified in Question 

number 3. 

According to the applicant, “There are no plans to change locations, primarily because the classes will also be 

offered on-line to provide access to a diverse population”.

Based on the information provided, no determination regarding this matter is warranted.

Notification of Lawsuits/Complaints Filed Alleging Discrimination:

The applicant provided an authorizing official’s signature on SBCR’s Compliance Form B indicating his/her 

agreement to:

·	 Promptly notify NRC/SBCR upon its request of any lawsuit filed against the applicant or recipient 

alleging discrimination on the basis of race, sex, color, national origin, disability, religion, age, sexual 

orientation, or status as a parent. 

·	 Promptly notify NRC/SBCR upon its request of any complaints filed against the recipient alleging 

discrimination.

·	 Submit compliance reports upon the agency’s request to the Nuclear Regulatory Commission Office of 

Small Business and Civil Rights (SBCR). The applicant also agreed to submit an annual EO compliance 

report to SBCR no later than December 31 of each calendar year.

·	 Provide comprehensive civil rights training for staff, and periodically retrain staff to establish and update 

their knowledge of EO civil rights statues and emerging issues.

Based on the information submitted, SBCR has determined that the information/documentation provided is 

sufficient to satisfy this area of inquiry.

Applications for Federal Financial Assistance:

According to the applicant’s response on the NRC 781 Form, Part B, “The Institution has no pending 

applications for financial assistance with Federal agencies”. 

An in-depth review and analysis of the applicant’s file confirmed that the Institution has pending applications for 

financial assistance with Federal agencies, including: Agency # 1, Agency # 2 and Agency # 3.

The applicant was notified of its Federal funding status in a follow up review on Month-Day-Year. The confirmed 

information is recorded in the applicant’s file.

According to the applicant’s response on SBCR’s Compliance Form B, “No civil rights compliance reviews have 

been conducted during the two-year period before this application and that no findings of a noncompliance with 

any relevant civil rights requirements occurred”. 

In a follow-up review with the applicant, the authorized representative was notified that the information 

submitted in response to the inquiry was incorrect. According to the applicant, “I am fairly new to this position 

and was not aware of any prior reviews but will research SBCR’s findings right away and I will provide an 

amended response before Close of Business today”. 

On Month-Day-Year, the applicant submitted an amended response which confirmed SBCR initial findings and 

sufficiently satisfied the inquiry in question.

SAMPLE
28 | Page

Agreement to Compile and Maintain Records:

The applicant provided his/her full name, title, date and signature on SBCR’s Compliance Form B indicating 

his/her agreement to compile and maintain the records required, pursuant to NRC’s guidelines, and other Civil 

Rights directives is required. 

Based on the information submitted and additional findings, SBCR has determined that sufficient information/

documentation to satisfy this area of inquiry is pending.

Additional Title IX Information (SBCR Compliance Review Part C)

The undersigned review the aforementioned section of Part C. In doing so, notified the applicant that data 

collections imposed under Title IX of the Educational Amendments of 1972 and the Nuclear Regulatory 

Commission Title IX implementing Regulations (NRC) set forth inTitle10 of the Code of Federal Regulations, 

Part 5. Except as provided in §§5.205 through 5.235(a), of NRC’s Title IX regulations, these requirements 

apply to every recipient and to each education program or activity operated by a recipient that receives Federal 

financial assistance.

The applicant checked the box on the stated Form indicating that the institution does provide some types(s) of 

education programs or activities. The undersigned confirmed the applicant’s response verbally and in writing. 

The applicant also affixed his/her signature on SBCR’s Compliance Form C indicating his/her agreement to:

·	 Provide assurance that all of the recipient’s education programs or activities will be operated in 

compliance with the nondiscrimination mandates of Title IX and NRC’s implementing regulations 

(e.g., Admissions and Recruitment. See §§5.300 through 5.310; Education Programs or 

Activities. See §§5.400 through 5.455; and Employment in Education Programs or Activities. See 

§§5.500 through 5.550).

·	 Provide assurance that the recipient will take whatever remedial action is necessary in 

accordance with §5.110(a) to eliminate existing discrimination on the basis of sex or to eliminate 

the effects of past discrimination whether occurring prior to or subsequent to the assurance 

given.

·	 Provide assurance that the assurances in this section will be required of the applicant or recipient 

sub-grantees, contractors, subcontractors, transferees, or successors in interest.

Applicants are required to Designate a Title IX Coordinator, Notification to Students and Employees and 

Adoption of Grievance Procedures to Fulfill Requirements Under §5.135 and Title IX:

The applicant affixed his/her signature on SBCR’s Compliance Form C indicating his/her agreement to:

·	 Designate at least one responsible employee to coordinate Title IX compliance efforts and carry 

out the recipient’s responsibilities under Title IX and NRC’s implementing regulations, including 

coordinating any investigations of complaints or noncompliance with Title IX regulations.

·	 Continue to provide notification to all of the recipient’s students and employees of the name, 

office address, and telephone number of the employee or employees designated to coordinate 

the recipient’s Title IX efforts.

·	 Adopt and publish an internal grievance procedure to determine whether a particular act, policy, 

or practice of the recipient complies with Title IX regulations; and that promptly and equitably 

resolves complaints alleging discrimination on the basis of sex in education programs or 

activities.

SAMPLE
Page | 29

Applicants are required to Disseminate Title IX Policy to Fulfill Requirements Under §5.140 and Title IX:

The applicant affixed his/her signature on SBCR’s Compliance Form C indicating that the institution:

·	 Has taken specific steps to regularly and consistently notify the public - i.e., participants, 

employees, applicants, etc. that the recipient does not discriminate on the basis of sex in the 

operation of its education programs and activities; Title IX and Title IX regulations also apply to 

employment in and admission to the recipient’s education programs and activities; and inquiries 

regarding Title IX and Title IX regulations may be referred to the recipient’s designated Title IX 

Coordinator, or Federal funding agency/official (i.e., Nuclear Regulatory Commission Office of 

Small Business and Civil Rights).

·	 Prominently publishes a statement of the Title IX policy described in this section in each 

announcement, bulletin, catalog, or application form that the recipient makes available to the 

public or that is used in connection with any recruitment of students or employees.

·	 Ensures that the notification is widely disseminated and easily understood.

·	 Ensures that the recipient does not use or distribute a publication that suggests by its text or 

illustration that it treats applicants, students or employees differently on the basis of sex-except 

as permitted under the Title IX regulations.

·	 Distributes the recipient’s Title IX policies without discrimination on the basis of sex, informs each 

of its admission and employment recruitment representatives of the Title IX nondiscrimination 

policies, and requires that the representatives adhere to the policies.

Based on the information submitted and additional findings, SBCR has determined that the applicant provided 

sufficient information/documentation to satisfy this area of inquiry.

SF424B Assurances:

SBCR’s review also included verification of NRC’s receipt of the Application of Federal Assistance (SF424B), 

and that the applicant’s authorized certifying official’s signature was affixed to the document.

SBCR Staff Recommendation:

Based on the overall findings, sufficient evidence exists to determine that the applicant is in compliance with 

applicable Federal Civil Rights statutes.

1st Level Reviewer of File: Civil Rights Specialist Name Date: ___________ 

Submitted for 2nd Level Review: Date: ___________

2nd Level Reviewer of File: Tuwanda M. Smith, Esq., Program Mgr. Date: ___________ 

The Originator of Summary Report: Civil Rights Specialist Name Date: ___________

Concurrence: Date: 

 

Comments:

SAMPLE

APPENDIX E – NOTICE TO AMD THAT APPLICANT(S) ARE IN COMPLIANCE

Page | 33

APPENDIX E – NOTICE TO AMD THAT APPLICANT(S) ARE IN COMPLIANCE

SAMPLE

APPENDIX F – NOTICE TO AMD THAT APPLICANT(S) HAVE BEEN 

PLACED IN PERIODIC STATUS

Page | 37

APPENDIX F – NOTICE TO AMD THAT APPLICANT(S) HAVE BEEN 

PLACED IN PERIODIC STATUS

SAMPLE

APPENDIX G – NOTICE TO AMD OF CONTINUATION OF PERIODIC STATUS

Page | 41

APPENDIX G – NOTICE TO AMD OF CONTINUATION OF PERIODIC STATUS
42 | Page

SAMPLE
APPENDIX H – NOTICE TO AMD OF REMOVAL FROM PERIODIC STATUS

Page | 45

APPENDIX H – NOTICE TO AMD OF REMOVAL FROM PERIODIC STATUS

APPENDIX I – CRITERIA/DATA COLLECTION FORM USED TO TARGET

 RECIPIENTS FOR ONSITE AUDIT

Page | 49

APPENDIX I – CRITERIA/DATA COLLECTION FORM USED TO TARGET

 RECIPIENTS FOR ONSITE AUDIT

Criteria/Data Collection Form Use to Target Recipients for Onsite Audit

SAMPLE

APPENDIX J – POST-AWARD COMPLIANCE ASSESSMENT—REQUEST TO

CONDUCT ONSITE VISIT

Page | 53

APPENDIX J – POST-AWARD COMPLIANCE ASSESSMENT—REQUEST TO

CONDUCT ONSITE VISIT

UNITED STATES

NUCLEAR REGULATORY COMMISSION 

Equal Opportunity Coordinator 

University of Example

1234 Main Street

Anytown, USA 12345

SUBJECT: POST-AWARD COMPLIANCE REVIEW ASSESSMENT U.S. NUCLEAR

 REGULATORY COMMISSION GRANT RECIPIENT

Dear Equal Opportunity Coordinator:

The U.S. Nuclear Regulatory Commission (NRC) is responsible for providing regulatory 

oversight of, coordinating compliance with, and enforcing Title VI of the Civil Rights Act of 

1964, including the provisions related to limited English proficiency; Title IX of the Educational 

Amendments Act of 1972; Sections 504 and 508 of the Rehabilitation Act of 1973, as amended; 

the Age Discrimination Act of 1975; and Title IV of the Atomic Energy Act of 1954, as amended. 

These acts are adopted and incorporated in NRC regulations under Title 10 of the Code of 

Federal Regulations (10 CFR) Part 4, “Nondiscrimination in Federally Assisted Programs or 

Activities Receiving Federal Financial Assistance from the Commission,” and 10 CFR Part 5, 

“Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal 

Financial Assistance.” 

The Office of Small Business and Civil Rights (SBCR) administers NRC civil rights compliance 

programs. SBCR is required to establish and maintain effective pre- and post-award 

compliance review programs to ensure that award recipients comply with Federal mandates and 

nondiscrimination laws.

On December 31, 20XX, SBCR received your annual equal opportunity compliance report. SBCR 

used this report, along with independent research and other data, to conduct a post award desk 

audit. Based on the review conducted, SBCR has determined that your programs adequately 

meet Federal requirements; however, issues of significance require clarification or additional 

information before we can make a final determination. Therefore, SBCR requests an onsite audit 

to reconcile these issues and concerns. A member of the Outreach and Compliance Coordination 

staff will contact you in the near future to schedule a site visit.

SAMPLE
54 | Page

If you have any questions or need additional information, please contact Tuwanda M. Smith, Esq., 

Manager, Outreach and Compliance Coordination Program at (301) 415-7394, or via email at 

Tuwanda.Smith@nrc.gov. 

 Sincerely,

 Vonna L. Ordaz, Director

Office of Small Business and Civil Rights

SAMPLE
APPENDIX K – POST-AWARD COMPLIANCE ASSESSMENT—

REQUEST FOR ADDITIONAL INFORMATION

Page | 57

APPENDIX K – POST-AWARD COMPLIANCE ASSESSMENT—

REQUEST FOR ADDITIONAL INFORMATION

UNITED STATES

NUCLEAR REGULATORY COMMISSION

Equal Opportunity Coordinator

University of Example

1234 Main Street

Anytown, USA 12345

SUBJECT: POST-AWARD COMPLIANCE REVIEW ASSESSMENT U.S. NUCLEAR 

 REGULATORY COMMISSION GRANT RECIPIENT

Dear Equal Opportunity Coordinator:

The U.S. Nuclear Regulatory Commission (NRC) is responsible for providing regulatory 

oversight of, coordinating compliance with, and enforcing Title VI of the Civil Rights Act of 

1964, including the provisions related to limited English proficiency; Title IX of the Educational 

Amendments Act of 1972; Sections 504 and 508 of the Rehabilitation Act of 1973, as amended; 

the Age Discrimination Act of 1975; and Title IV of the Atomic Energy Act of 1954, as amended. 

These acts are adopted and incorporated in NRC regulations under Title 10 of the Code of 

Federal Regulations (10 CFR) Part 4, “Nondiscrimination in Federally Assisted Programs or 

Activities Receiving Federal Financial Assistance from the Commission,” and 10 CFR Part 5, 

“Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal 

Financial Assistance.” 

The Office of Small Business and Civil Rights (SBCR) administers NRC civil rights compliance 

programs. SBCR is required to establish and maintain effective pre- and post-award 

compliance review programs to ensure that award recipients comply with Federal mandates and 

nondiscrimination laws.

On December 31, 20XX, SBCR received your annual equal opportunity compliance report. SBCR 

used this report, along with independent research and other data, to conduct a post award desk 

audit. Based on the review conducted, SBCR has determined that your programs adequately 

meet Federal requirements; however, a few issues require clarification or additional information 

before we can make a final determination. A member of the Outreach and Compliance Program 

(OCCP) will contact you shortly to discuss this matter.

SAMPLE
58 | Page

Questions or requests or additional information may be sent in writing to:

U.S. Nuclear Regulatory Commission 

Office of Small Business and Civil Rights 

Outreach and Compliance Coordination Program 

11545 Rockville Pike

Mailstop: O3H06

Rockville, Maryland 20852

E.O. Coordinator 

You may also contact the Outreach and Compliance Coordination staff at XXX-XXX-XXXX, or via 

email at OCCPrograms.Resource@nrc.gov.

 Sincerely,

 Vonna L. Ordaz, Director

Office of Small Business and Civil Rights SAMPLE
APPENDIX L – POST-AWARD COMPLIANCE ASSESSMENT—

DETERMINATION LETTER OF COMPLIANCE WITH REGULATIONS

Page | 61

APPENDIX L – POST-AWARD COMPLIANCE ASSESSMENT—

DETERMINATION LETTER OF COMPLIANCE WITH REGULATIONS

UNITED STATES

NUCLEAR REGULATORY COMMISSION

Equal Opportunity Coordinator 

University of Example

1234 Main Street

Anytown, USA 12345

SUBJECT: POST-AWARD COMPLIANCE REVIEW ASSESSMENT U.S. NUCLEAR 

 REGULATORY COMMISSION GRANT RECIPIENT

Dear Equal Opportunity Coordinator:

The U.S. Nuclear Regulatory Commission (NRC) is responsible for providing regulatory 

oversight of, coordinating compliance with, and enforcing Title VI of the Civil Rights Act of 1964, 

including the provisions related to environmental justice and limited English proficiency; Title IX of 

the Educational Amendments Act of 1972; Sections 504 and 508 of the Rehabilitation Act of 1973, 

as amended; the Age Discrimination Act of 1975; and Title IV of the Atomic Energy Act of 1954, 

as amended. These acts are adopted and incorporated in NRC regulations under Title 10 of the 

Code of Federal Regulations (10 CFR) Part 4, “Nondiscrimination in Federally Assisted Programs 

or Activities Receiving Federal Financial Assistance from the Commission,” and 10 CFR Part 5, 

“Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal 

Financial Assistance.” 

The Office of Small Business and Civil Rights (SBCR) administers NRC civil rights compliance 

programs. SBCR is required to establish and maintain effective pre- and post-award 

compliance review programs to ensure that award recipients comply with Federal mandates and 

nondiscrimination laws.

On December 31, 20XX, SBCR received your annual equal opportunity compliance report. SBCR 

used this report, along with independent research and other data, to conduct a post award desk 

audit. Based on the review conducted, SBCR has determined that your programs adequately 

meet Federal requirements. We look forward to your continued participation in NRC sponsored 

programs.

SAMPLE
62 | Page

Questions or requests for additional information may be sent in writing to:

U.S. Nuclear Regulatory Commission

Office of Small Business and Civil Rights

Outreach and Compliance Coordination Program

11545 Rockville Pike

Mailstop: 03H06

Rockville, Maryland 20852

E.O. Coordinator 

You may also contact the Outreach and Compliance Coordination staff at XXX-XXX-XXXX, or via 

email at OCCPrograms.Resource@nrc.gov. 

 Sincerely,

 Vonna L. Ordaz, Director

Office of Small Business and Civil Rights SAMPLE
BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(12-2010)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

3. DATE REPORT PUBLISHED

MONTH YEAR

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

5. AUTHOR(S) 6. TYPE OF REPORT

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address; if 

 contractor, provide name and mailing address.)

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U. S. Nuclear Regulatory 

 Commission, and mailing address.)

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

NUREG-2186

Compliance Review Guide

December 2015

Tuwanda M. Smith, Esq. Technical

Office of Small Business and Civil Rights 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001

Same as above

This manual assists the U.S. Nuclear Regulatory Commission (NRC) to ensure Procedural Processes for Conducting Pre-award 

Compliance Reviews and Post-award Compliance Reviews

NRC's Compliance Review Guide 
NUREG-2186 

December 2015