DEPARTMENTAL DIRECTIVE

ADMINISTRATIVE

COMMUNICATIONS SYSTEM

U.S. DEPARTMENT OF EDUCATION

DEPARTMENTAL DIRECTIVE 

ACSH-OFO-006Page 1 of 369 (DATE) 

Distribution: 

All Department of Education 

Employees

Approved by: __________________________

Denise L. Carter Delegated the 

Duties of Assistant Secretary 

Office of Finance and 

Operations

Handbook for the Discretionary Grant Process 

Table of Contents

Handbook for the Discretionary Grant Process ............................................................... 1

Chapter 1: Introduction................................................................................................. 7

1.1 Overview ........................................................................................................ 7

1.2 Format of the Handbook................................................................................. 7

1.3 Applicability..................................................................................................... 8

1.4 GMPD Responsibilities................................................................................... 9

1.5 Maintenance................................................................................................. 10

1.6 For-Profit Organizations ............................................................................... 11

1.7 Recordkeeping Requirements Related to the Grants Process ..................... 14

Chapter 2: Planning Activities .................................................................................... 17

2.1 Introduction................................................................................................... 17

2.2 Planning Activities ........................................................................................ 17

2.2.1 Principal Office Spending Plan ..................................................................... 17

2.2.2 Grant Schedules............................................................................................ 19

2.2.3 Assistance Listing Numbers (ALNs) ............................................................. 21

2.2.4 Funding Down the Slate (from previous or same year competition) ............. 22

2.2.5 Competition Planning and Pre-Clearance Meetings..................................... 25

2.3 Developing Regulatory Documents .............................................................. 27

2.4 Grant Program Performance Measures........................................................ 29

2.5 Application Packages and Notices ............................................................... 30

2.5.1 Application Packages ................................................................................... 30

2.5.2 Changes to an Approved Program-Specific Application Package ................ 37

2.5.3 Notifying Applicants of ED’s Indirect Cost Requirements ............................. 39

2.5.4 Sources of Funding Information.................................................................... 40

2.5.5 Evidence Reviews ........................................................................................ 41
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2.5.6 Notices Inviting Applications (NIAs).............................................................. 47

2.5.7 Communication with the Public about Competitions..................................... 51

2.5.8 General Education Provisions Act (GEPA) – Section 427 ............................ 54

2.5.9 Grants.gov.................................................................................................... 55

2.5.10 Electronic Application Processing for Fellowships or Exceptions ................. 57

2.6 Novice Applicants and New Potential Grantees ........................................... 58

2.6.1 Novice and New Potential Grantees Application Procedures ....................... 58

2.6.2 Separate Competitions for Novice and New Potential Grantees .................. 62

2.6.3 Competitive Preference for Novice and New Potential Grantees ................. 62

2.6.4 Novice and New Potential Grantees Designation and Certification .............. 63

2.6.5 Pre-Application Technical Assistance for Novice Applicants and New 

Potential Grantees........................................................................................ 65

2.6.6 Special Conditions for Novice Applicants ..................................................... 65

2.7 Faith-Based Organizations ........................................................................... 66

2.8 Proving Non-profit Status ............................................................................. 68

2.9 Funding Definitions and Periods of Funding................................................. 69

2.9.1 Appropriations .............................................................................................. 69

2.9.2 Frontloading versus Forward Funding.......................................................... 70

2.9.3 Project Periods ............................................................................................. 72

2.9.4 Budget Periods............................................................................................. 73

Chapter 3: Review Activities....................................................................................... 75

3.1 Introduction................................................................................................... 75

3.2 Developing and Approving the ATRP........................................................... 75

3.2.1 Developing the ATRP................................................................................... 75

3.2.2 Contents of the ATRP................................................................................... 77

3.3 Developing, Maintaining, and Closing the Grant Program Competition File . 81

3.4 Receiving and Screening Applications ......................................................... 84

3.4.1 Applications Submitted Electronically ........................................................... 85

3.4.2 Applications Submitted Via Grants.gov ........................................................ 86

3.4.3 Extending Application Deadline Dates for Exceptional Circumstances ........ 88

3.4.4 Standards for Reviewing Applications .......................................................... 89

3.5 Peer Reviewers ............................................................................................ 91

3.5.1 One Percent Set-Aside for the Peer Review ................................................ 91

3.5.2 Inherently Governmental Functions and Contractors ................................... 94

3.5.3 Factors to Consider in Recruiting and Selecting Peer Reviewers................. 97

3.5.4 Recruiting Peer Reviewers for the Reviewer Database................................ 99

3.5.5 Selecting Reviewers for a Reviewer Roster ............................................... 100

3.5.6 Using Reviewers in Consecutive Application Review Cycles ..................... 101

3.5.7 Packages for Peer Reviewers .................................................................... 102

3.5.8 Qualifications and Training for Managing a Grant Competition .................. 103

3.5.9 Roles and Responsibilities in the Review Process ..................................... 107

3.5.10 Orientation of Peer Reviewers.................................................................... 109

3.5.11 Confidentiality of the Review Process ........................................................ 111

3.5.12 Replacement of Reviewers During the Review........................................... 112

3.6. Conflict of Interest....................................................................................... 114
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3.6.1 Reviewing Reviewer Information for Conflicts of Interest ........................... 114

3.6.2 Reviewers with Conflicts of Interest............................................................ 116

3.6.3 Conflicts Related to Applications from a Consortium of Entities ................. 118

3.6.4 Conflicts Related to State University Systems and Multiple Campuses ..... 119

3.6.5 Conflict of Interest Exemption for Large Competitions................................ 119

3.6.6 Individual Conflict of Interest Waivers......................................................... 120

3.6.7 Waiver Restrictions .................................................................................... 122

3.6.8 Reviewers Who Are Federal Employees .................................................... 122

3.6.9 Process for Addressing Other Factors That Might Affect Objectivity .......... 123

3.7 Peer Review Scoring and Quality Control .................................................. 126

3.7.1 Limiting the Standardization of Peer Reviewers’ Scores ............................ 126

3.7.2 Ensuring the Consistency and Quality of Peer Reviewer Scoring .............. 127

3.7.3 Scoring Rubrics .......................................................................................... 131

3.7.4 Peer Reviewer Oversight............................................................................ 133

3.7. Peer Reviewer Evaluation .......................................................................... 136

3.8 Multiple-Tier Application Reviews............................................................... 137

3.9 e-Reader – Peer Review System ............................................................... 139

Chapter 4: Pre-Award Activities ............................................................................... 142

4.1 Pre-Award Activities Applicable to All Programs - Introduction................... 142

4.2 Rank Order: Preparing a Preliminary Rank Order Based on Peer Review 

Scores ........................................................................................................ 142

4.3 Program Office Review of Applications ...................................................... 143

4.4 Unique Entity Identifier (UEI) reviews in SAM - General............................. 146

4.5 Clarification Contacts.................................................................................. 146

4.6 Evaluating Grant Applicant Risk Prior to Making New Grant Awards ......... 149

4.6.1 Reviewing Audit Data Prior to Making New Awards ................................... 154

4.6.2 Key Personnel Qualifications Review & Excluded Parties List ................... 155

4.6.3 Determining Applicant Competence and Responsibility ............................. 157

4.6.4 FAPIIS Information Review Requirements ................................................. 159

4.7 Certification of Eligibility for Federal Assistance in Certain Programs ........ 161

4.8 Review of Lobbying Certification and Disclosure Forms............................. 162

4.9 Cost Analysis and Budget Review.............................................................. 163

4.9.1 Budget Analysis and the Grants Management System– General............... 163

4.9.2. Key Personnel and Level of Effort in the Grants Management System...... 165

4.9.3 Direct Costs................................................................................................ 167

4.10 Pre-Award Activities Implemented When Applicable - Introduction ............ 168

4.10.1 Grantee Cost Sharing or Matching (Non-Federal Share) ........................... 168

4.10.2 Waiving Required Cost Sharing or Matching.............................................. 171

4.10.3 Calculating Cost Sharing or Matching Amounts ......................................... 172

4.10.4 Pre-award Costs......................................................................................... 174

4.10.5 Program Income......................................................................................... 176

4.10.6 Indirect Costs – General............................................................................. 178

4.10.7 Indirect Costs – When They Apply ............................................................. 180

4.10.8 Reviewing Indirect Cost Information During Cost Analysis......................... 182

4.10.9 Indirect Costs – Temporary Rates Plus Negotiated Agreements................ 184
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4.10.10 Indirect Costs – Temporary Rates – Retroactive Recovery..................... 185

4.10.11 Indirect Costs – De Minimis Rate – No Negotiation................................. 186

4.10.12 Indirect Costs – Training Grants .............................................................. 187

4.10.13 Indirect Costs – Restricted Rate Programs.............................................. 188

4.10.14 Administrative Cost Cap .......................................................................... 190

4.11 Protection of Human Subjects .................................................................... 192

Chapter 5: Award Activities ...................................................................................... 197

5.1 Introduction................................................................................................. 197

5.2 Funding Recommendations........................................................................ 197

5.2.1 Developing Funding Recommendations..................................................... 197

5.2.2 Selecting Applications for Funding ............................................................. 198

5.2.3 Grant Funding Slate - New Grants ............................................................. 199

5.3 UEI Registration Reviews in SAM – Pre-Obligation.................................... 200

5.4 Qualifications Needed to Commit, Obligate and Award Grants .................. 202

5.4.1 General....................................................................................................... 202

5.4.2 Qualifications of Individuals Who Commit Funds........................................ 203

5.4.3 Qualifications of Individuals Who Record Obligations and Award Grants... 204

5.4.4 Requesting a License to Obligate Funds.................................................... 206

5.4.5 Maintaining and Updating the License........................................................ 207

5.4.6 Revoking or Canceling a License to Obligate Funds.................................. 209

5.5 Commitment, Obligation and Award Functions........................................... 210

5.5.1 General....................................................................................................... 210

5.5.2 Recording Commitments ............................................................................ 211

5.5.3 Congressional Notification.......................................................................... 212

5.5.4 License Holder Review Prior to Obligations and Issuing New Awards ....... 213

5.5.5 Grant Award Terms and Conditions Related to FAPIIS.............................. 216

5.5.6 Electronic Signature for Grant Awards ....................................................... 217

5.5.7 Requirements for Awarding a Grant ........................................................... 218

5.6 Notifying Applicants .................................................................................... 219

5.6.1 Notifying Successful Applicants.................................................................. 219

5.6.2 Notifying Unsuccessful Applicants.............................................................. 220

5.6.3 Appeals by Unsuccessful Applicants.......................................................... 221

5.7 The Official Grant File................................................................................. 222

5.8 Transparency.............................................................................................. 226

5.8.1 Increasing Transparency of the Competitive Award Process ..................... 226

5.8.2 Redacting Personally Identifiable and Proprietary Information ................... 230

5.9 Issuing Hard Copy GANs for New Awards ................................................. 231

5.10 Cooperative Agreements – General ........................................................... 232

5.10.1 Determining Substantial Involvement......................................................... 234

5.10.2 Alternating Award Instruments.................................................................... 234

5.11 Other Awards.............................................................................................. 235

5.11.1 Directed Awards (Earmarks)....................................................................... 235

5.11.2 Unsolicited Applications.............................................................................. 237

5.11.3 Mishandled Applications............................................................................. 239

Chapter 6: Post-Award Activities.............................................................................. 241
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6.1 Introduction................................................................................................. 241

6.2 Post-Award Conference ............................................................................. 241

6.3 Monitoring................................................................................................... 245

6.3.1 Monitoring Introduction ............................................................................... 245

6.3.2 General Requirements, Guidance, and Other Pertinent Information .......... 245

6.3.3 Program Monitoring Plans .......................................................................... 248

6.3.4 Program Technical Assistance Plans ......................................................... 253

6.3.5 Evaluating Risk during Monitoring .............................................................. 254

6.3.6 Reviewing Audit Information during Monitoring .......................................... 257

6.3.7 Adverse Findings Requiring Consultation with Other Offices ..................... 259

6.3.8 Debarment and Suspension during Monitoring .......................................... 260

6.3.9 Monitoring Reports ..................................................................................... 261

6.4 Monitoring – Financial ................................................................................ 262

6.4.1 Excessive Drawdown ................................................................................. 265

6.4.2 Payment Flags............................................................................................ 270

6.4.3 Large Available Balance............................................................................. 272

6.4.4 Cost Sharing and Matching Contributions .................................................. 275

6.5 Monitoring - Subaward and Executive Compensation Reporting Required by 

FFATA ........................................................................................................ 278

6.6 Monitoring – Contracts and Procurements ................................................. 279

6.7 Non-Competing Continuation (NCC) Awards ............................................. 280

6.7.1 Evaluating Risk Prior to Making NCC Awards ............................................ 280

6.7.2 Reviewing Audit Data Prior to NCC Awards ............................................... 282

6.7.3 Reviewing Information in FAPIIS Prior to Making NCC Awards ................. 284

6.7.4 Making Non-Competing Continuation (NCC) Awards................................. 285

6.7.5 Annual Performance Reports and Due Dates ............................................ 287

6.7.6 Research Performance Progress Report.................................................... 290

6.7.7 Federal Financial Report SF 425 (FFR) ..................................................... 291

6.7.8 Substantial Progress .................................................................................. 293

6.7.9 Setting the NCC Award Amount ................................................................. 296

6.7.10 Carryover.................................................................................................... 297

6.8 Grant Administration................................................................................... 299

6.8.1 Grantee Flexibility with Administrative Actions ........................................... 299

6.8.2 Administrative Actions Requiring Prior Approval from ED .......................... 300

6.8.3 Grantees’ Technical Changes that Do Not Require Prior Approval ............ 303

6.8.4 Restricting Grantee Flexibilities under 2 C.F.R. § 200.308......................... 304

6.8.5 Changes to Key Personnel......................................................................... 305

6.8.6 Revising Grantee Cost Sharing or Matching .............................................. 306

6.8.7 Prohibiting Changes to the Project Scope or Objectives of a Grant ........... 308

6.8.8 Data Collection Period – EDGAR § 75.250(b)............................................ 309

6.9 Publications ................................................................................................ 311

6.10 Open Licensing Requirements ................................................................... 311

6.11 Supplemental Awards................................................................................. 313

6.12 Grant Transfers .......................................................................................... 318

6.13 Extensions of the Final Budget Period........................................................ 321
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6.13.1 One-Time Extensions Authorized in EDGAR § 75.261(a) .......................... 321

6.13.2 One-Time No-Cost Extensions Exceeding 12 Months................................ 324

6.13.3 Subsequent No-Cost Extensions................................................................ 327

6.14 Grant Performance – Addressing Risk and Other Issues ........................... 328

6.14.1 Enforcement ............................................................................................... 328

6.14.2 Required Notification to Grantees............................................................... 333

6.15 Risk Module................................................................................................ 337

6.16 Grant Closeout – General........................................................................... 339

6.16.1 Grant Closeout Processes....................................................................... 341

6.17 Processing a Reinstatement....................................................................... 348

6.18 Sharing Results .......................................................................................... 350

6.19 Freedom of Information Act (FOIA) Request .............................................. 351

6.20 Internal Review of ED’s Discretionary Grant Processes............................. 353

GLOSSARY ............................................................................................................. 355

ACRONYMS and ABBREVIATIONS APPEARING in this HANDBOOK .................. 371

Questions about this Handbook may be addressed to the OAGRM/GMPD liaisons found 

at GMPD Liaisons.

Supersedes Handbook OCFO-03 “Handbook for the Discretionary Grant Process” dated 

07/23/2020. 

This Handbook, including all its appendices, has the same authority as the handbook 

that it supersedes.
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Chapter 1: Introduction

1.1 Overview

This Handbook for the Discretionary Grant Process (Handbook) provides the 

foundation and framework for the ED discretionary grant process. It provides 

consistent policies, standards, and procedures for ED’s discretionary grant 

programs to ensure that ED awards and administers Federal funds in a fair and 

equitable manner across every program.

This Handbook establishes the internal policies and procedures that program 

offices use to carry out the discretionary grant functions of planning, reviewing, 

selecting and awarding applications, ensuring grantee accountability, sharing 

results, and closing out grants. Program offices obligate, administer, and monitor 

these awards under a variety of legislative authorities, governing regulations, 

policies, and procedures.

The policies and procedures outlined in this Handbook are intended to ensure 

consistency across ED program offices, where possible, and compliance with 

statutory and regulatory requirements that govern how ED administers 

discretionary grants.

1.2 Format of the Handbook

Throughout this Handbook, information may be identified under the major 

headings: “Policy,” “Procedures,” “Guidance,” and “Other Pertinent Information.”

The “Policy” heading identifies implementation and compliance requirements 

related to the Planning, Review, Pre-Award, Award, and Post-Award stages of the 

grant administration process.

The “Procedures” heading identifies required approaches, methodologies, and 

processes to accomplish required tasks or to comply with policy.

The “Guidance” heading provides information to assist with implementing and 

complying with related policy. While these sections include best practices or 

suggested actions or tasks they are not required.

The “Other Pertinent Information” heading provides explanatory or general 

information on a policy topic or procedure that may not directly fit under the other 

headings.

While each of these headings will appear within every topic area addressed 

within this Handbook, not all headings will include information as herein described. 

The headings without information appearing underneath them are included as 
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“reserved” headings for future use, so that when information that is applicable arises, 

it can be placed under the heading.

1.3 Applicability

A. Policy

1. The policies and procedures in this Handbook apply to all organizational units 

in ED responsible for planning, reviewing, selecting, and awarding 

applications, ensuring grantee accountability, sharing results, and closing out 

grants.

2. Nothing in this Handbook is intended to give grant applicants or grantees any 

rights not already provided by statutes, regulations, or published program 

priorities.

3. Program offices follow the policies and procedures outlined in this Handbook 

and monitor compliance with this Handbook as a part of their internal control 

program. A program office, in limited circumstances, may determine that a 

modification to, or a deviation from, these policies and procedures is 

appropriate to achieve a program objective or deal with unusual, 

unanticipated, or exigent circumstances.1

B. Procedures

1. When modifications or deviations from a policy or procedure are deemed 

appropriate, program offices consult with their program attorney to ensure the 

modification or deviation has no legal implications, and their Grant 

Management Policy Division (GMPD) liaison in the Office of Acquisition,

Grants and Risk Management (OAGRM) of the change to address policy 

concerns prior to making the modification or deviation. As appropriate, the 

program attorney and OAGRM consult with the Office of Planning Evaluation 

and Policy Development, Grants Policy Office, (OPEPD/GPO) as well as 

other offices prior to approving the modification. Depending on the type of 

permitted modification or deviation from the Handbook, program offices will 

then document the decision not to follow the Handbook in the Application 

Technical Review Plan (ATRP), the Grant Program Competition File, and/or 

the official grant file, as appropriate. These modifications and deviations are 

only considered in limited circumstances (e.g., when necessary to achieve a 

program objective that cannot otherwise be achieved or to deal with unusual, 

1 The Institute of Education Sciences (IES), because of the provisions set out in the Education Sciences 

Reform Act of 2002, as well as the unique needs of grants administered by IES, has its own “Procedures 

for the Peer Review of Grant Applications,” which were adopted by the National Board for Education 

Sciences on January 24, 2006. For grants administered by IES, those procedures, as well as other 

procedures uniquely applicable to IES, would to the extent there is an inconsistency with the policies, 

procedures, and guidance set out in this Handbook, take precedence.
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unanticipated, or exigent circumstances), and if they do not violate any laws 

or regulations.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

1.4 GMPD Responsibilities

A. Policy

1. GMPD ensures that policies and procedures relative to discretionary grant

award and administration processes are effectively communicated to Principal 

Operating Components (POCs) ED-wide and assists POCs in their efforts to 

adhere to these policies and procedures.

2. GMPD responsibilities include, but are not limited to, the following:

a. Establishing clear policies based on statutes, regulations, and other 

requirements (e.g., Presidential Executive Orders, Office of Management 

and Budget (OMB) memorandums, etc.) in collaboration with program 

offices, and other staff offices, as appropriate, to enable consistent policy 

interpretation and implementation on grant administration issues. Policies 

are issued in this Handbook or in Grant Bulletins (GBs) until such time as 

the GBs are fully incorporated into this Handbook. GBs are the 

mechanisms authorized for use by GMPD to update content in this 

Handbook in between the times the Handbook is updated and officially 

cleared by ED.

b. Providing training and technical assistance to program offices so that 

program offices have a working knowledge of grant policy and how it 

applies to different situations. This knowledge is necessary for effective 

grant administration.

c. Collaborating with program officials, responsible for grant programs, to 

achieve effective monitoring of grant programs and ensure that monitoring 

activities and processes are conducted with consistency and are 

compliant with ED regulations and policies.

d. Collaborating with program offices to conduct periodic reviews of the 

internal policies and procedures described in the Handbook.

e. Coordinating ED’s participation in interagency initiatives related to 

improving the grant-making process. This includes, but is not limited to, 

coordinating ED’s comments on work products for interagency grant policy 

initiatives, coordinating ED’s participation in work groups, and coordinating 
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ED’s participation in pilot and implementation efforts associated with these 

work products or activities.

f. Licensing program staff, who have demonstrated knowledge about 

discretionary grant procedures through enough training and experience, to 

obligate discretionary grant funds.

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

1.5 Maintenance 

A. Policy

GMPD maintains and updates this Handbook. This Handbook incorporates policy 

and guidance issued through GBs and memoranda, and it, in effect, rescinds the 

following:

1. GB 15-02: Subaward and Executive Compensation Reporting Requirements 

for U.S. Department of Education (ED) Grantees under the Federal Funding 

Accountability and Transparency Act (FFATA);

2. GB 16-01: Guidance for Entering Discretionary and Formula Grant 

Subprogram Titles into the (G5) Grant Planning and Scheduling Module;

3. GB 16-02: Reviewing Grant Applicant and Grantee Information in the Federal 

Awardee Performance and Integrity Information System (FAPIIS);

4. GB 18-01: U.S. Department of Education Grant Application Form for Project 

Objectives and Performance Measures Information (OMB Control Number: 

1894- 0017);

5. GB-19-01: The Official Grant File for Discretionary Grant Programs;

6. GB-19-02: Developing, Maintaining, and Closing the Grant Program 

Competition File; 

7. GB-19-03: Peer Reviewer Evaluation; 

8. Memorandum 19-02: Inactive Unique Entity Identifier (UEI) Registrations; and 

9. GB-21-01: Implementation of the 120-Calendar Day Liquidation Period 

Codified in 2 C.F.R. § 200.344 and Effective on November 12, 2020 
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B. Procedures

1. GMPD reviews and updates this Handbook periodically to incorporate any 

new ED discretionary grant regulations and policies or any changes to current 

regulations or policies.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

1.6 For-Profit Organizations

A. Policy

1. For-profit organizations (also called “commercial organizations”) are entities 

that are established with the intention or purpose of making a profit. They are 

generally subject to the same requirements and processes set out in this 

Handbook that apply to other entities.

2. For-profit organizations are subject to the requirements in 2 C.F.R. part 200 

subpart E, “Cost Principles,” and in EDGAR § 75.560 (a)(3), “General Indirect 

Cost Rates; Exceptions.”

3. Some program statutes do not authorize ED to make grants to for-profit 

organizations, and program offices must comply with these statutory 

requirements.

4. For-profit recipients are required to submit audited financial statements to ED 

as a part of the compliance audit. Recipients that have one or more awards 

are required to have a compliance audit for each of these awards. The 

compliance audit requirements are effective starting with the fiscal year in 

which the project period for this grant begins.

5. For for-profit recipients, financial statement and compliance audit submissions 

are due to ED within nine months of the recipients’ fiscal year-end dates. For 

recipients, the compliance audits are submitted, along with audited financial 

statements, to ED’s Audit Resolution Division at: 

AuditResolutionDivision@ed.gov. 

B. Procedures

1. Program offices, after a grant competition and the awards are made, send an 

email to AuditResolutionDivision@ed.gov providing information on awards to 

for-profit organizations that require audit submissions.

The email provides:
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a. PR/Award Number;

b. Name and address of the organization;

c. Unique Entity Identifier (UEI);

d. Amount of the Award;

e. Period of Performance; and

f. Audit Submission Due Date (due within nine months of the grants fiscal 

year- end date).

2. Program offices follow-up with grantees if required audits are not received by 

their due dates.

3. Program offices follow the policy and procedures in Chapter 4, “Reviewing 

Audit Data Prior to Making New Awards” and Chapter 6, “Reviewing Audit 

Data Prior to Issuing NCC Awards”.

4. For grants made to for-profit organizations, program offices must select in the

grants management system the “For-Profit” standard clause, which will cause 

the three clauses below to print on Grant Award Notifications (GANs):

Cost Principles for For-Profit Organizations GAN Clause

“For-profit organizations are subject to the requirements in 2 C.F.R. part 200 

subpart E, “Cost Principles. For the purpose of part 200, for-profits are considered 

grantees.

General Principles for Determining General Indirect Cost Rates for ForProfit Organizations GAN Clause

The principles for determining the general indirect cost rate that are applicable to 

for-profit organizations are found in 48 C.F.R. part 31 Contract Cost Principles and 

Procedures (EDGAR § 75.560 (a)(3)). 

Annual Audit Requirements for For-Profit Organizations

As a condition of this award, your for-profit organization is required to complete a 

compliance audit annually for any fiscal year it expends more than $750,000 in 

Federal funds, excluding funds received through procurement contracts with the 

Federal government. Expenditures associated with grant funds expended under 

contracts with third parties will be examined as part of this compliance audit.

For-profit recipients are required to submit audited financial statements to the 

Department as a part of the compliance audit. The compliance audit 
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generally should be coordinated with the recipient’s existing financial 

statement audit. Auditors do not need to conduct the financial statement 

audit in accordance with Generally Accepted Government Auditing Standards 

(GAGAS) but should instead conduct the financial statement audit in 

compliance with either Generally Accepted Auditing Standards (“GAAS”) or 

standards put in place by the Public Company Accounting Oversight Board 

(“PCAOB”). However, auditors must conduct the compliance audit in 

accordance with GAAS and GAGAS. If the recipient is a subsidiary for which 

separate financial statements are not available, the recipient may submit the 

financial statements of the consolidated group.

Recipients that have one or more awards are required to have a compliance 

audit for each of these awards. The compliance audits and related reporting 

will generally follow the requirements for a program specific audit as set forth 

in Chapter 14 of the AICPA Audit Guide Government Auditing Standards and 

Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards (Uniform Guidance), Subpart F, Audit 

Requirements. The compliance requirements subject to testing are expected 

to be similar to those mandated for nonprofit recipients under the Uniform 

Guidance, Management Decisions, 200.521, Appendix XI to Part 200 -

Compliance Supplement and include the following: activities allowed or unallowed, allowable costs/cost principles, cash management, Davis Bacon Act, 

eligibility, equipment and real property management, matching/level of 

effort/earmarking, period of availability of federal funds, 

procurement/suspension/debarment, program income, real property 

acquisition/relocation assistance, reporting, sub-recipient monitoring, and 

special tests and provisions.

C. Guidance – Reserved

D. Other Pertinent Information

1. The compliance audit referenced in Policy item 4, generally should be 

coordinated with the recipient’s existing financial statement audit. Auditors do 

not need to conduct the financial statement audit in accordance with 

Generally Accepted Government Auditing Standards (GAGAS) but should 

instead conduct the financial statement audit in compliance with either 

Generally Accepted Auditing Standards (“GAAS”) or standards put in place by 

the Public Company Accounting Oversight Board (“PCAOB”). However, 

auditors must conduct the compliance audit in accordance with GAAS and 

GAGAS. If the recipient is a subsidiary for which separate financial 

statements are not available, the recipient may submit the financial 

statements of the consolidated group.

2. The compliance audits and related reporting will generally follow the 

requirements for a program specific audit as set forth in Chapter 14 of the 
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AICPA Audit Guide Government Auditing Standards and Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for 

Federal Awards (Uniform Guidance), Subpart F, Audit Requirements. The 

compliance requirements subject to testing are expected to be similar to 

those mandated for non-profit recipients under the Uniform Guidance, 

Management Decisions, 200.521, Appendix XI to Part 200 - Compliance 

Supplement and include the following: activities allowed or un- allowed, 

allowable costs/cost principles, cash management, Davis Bacon Act, 

eligibility, equipment and real property management, matching/level of 

effort/earmarking, period of availability of federal funds, 

procurement/suspension/debarment, program income, real property 

acquisition/relocation assistance, reporting, sub-recipient monitoring, and 

special tests and provisions.

3. Program offices should review for additional information the Guidance and 

Decision Tree on Risk Mitigation When Applicants are Missing Single Audits

which includes OGC approved actions and specific conditions.

1.7 Recordkeeping Requirements Related to the Grants Process

A. Policy

1. Program offices create, maintain, and dispose of the official grant file and the 

grant program competition files in compliance with the Departmental Directive 

ACSD-OCIO-012, “Records and Information Management Program”); 44

U.S.C. Chapters 21, 29, 31, and 33; and 36 C.F.R. Chapter XII, Subchapter 

B, and applicable ED Comprehensive Records Retention and Disposition 

Schedules and National Archives and Records Administrative General 

Records Schedules (GRS).

a. These files are maintained in either ED’s grants management system, the 

Office 365 OneDrive (or any electronic platform succeeding the Office 365 

OneDrive that is designated by ED).

2. If a program official determines that a program office cannot use the grants 

management system to maintain the official grant files, the program office’s 

records liaison officer’s (as the position is described in Directive OM 6:103), is 

obligated to:

a. Inform the ED records officer in writing, on an annual basis, of the 

program official’s determination and the exact location of their ’s official 

grant files in the Office 365 OneDrive or in any succeeding electronic 

platform designated by ED.

b. Program offices, for circumstances in which maintaining hard copy 

documents and files is necessary, submit a request to receive a waiver to 
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the electronic recordkeeping requirement following the Procedures in the 

Applicability section.

B. Procedures

1. Program offices, where the Handbook requires a signature to indicate an 

action was taken (e.g., acceptance, concurrence, approval), either sign a 

paper document containing the relevant information or “sign” electronically in 

the grants management system, or in other ED information systems, after the 

electronic submission of relevant information into these systems has 

occurred.

2. Program offices scan and upload signed paper documents into the electronic 

grant files.

3. Program officials, to maintain documents and files in hard copy, make a 

compelling case in writing for an electronic recordkeeping waiver and include:

a. The unique circumstance that justifies the need for maintaining hard copy 

files and documents.

b. The procedures or steps to be taken in order to move towards electronic 

recordkeeping.

c. The date by which these documents and files will be filed electronically, if 

possible.

4. Program offices, before destroying paper grant files converted to electronic 

formats, obtain authorization from their program attorney and ED’s Records 

Officer.

5. Approved waivers and other documents required to be stored in grant or 

competition files are placed into these files timely (see the sections 

Developing, Maintaining, and Closing the Grant Program Competition File

and The Official Grant File).

C. Guidance

1. Program offices should maintain their official grant files in ED’s grants 

management system. This system is the preferred location because of 

unlimited document storage and because official grant file related processes 

are automated therein.

a. To foster increased electronic record retention, paper records should be 

converted contemporaneously with electronic records, and in accordance 

with applicable law, to electronic formats for the grants management 
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system or Office 365 OneDrive storage (or any electronic platform 

succeeding the Office 365 OneDrive that is designated by ED).

b. Program offices, if transitioning from one file site to another, should 

minimize the transition time in order to avoid the file being maintained in 

two locations.

2. Program offices should maintain their electronic grant files in the grants 

management system using the Post- Award Monitoring (PAM) component, 

and their grant competition files using the Grant Set-Up module.

3. Program offices, if maintaining files using a combination of paper-based and 

electronic formats, should have a method established for quickly identifying 

the location of these files and for quickly retrieving documents.

D. Other Pertinent Information

1. Although grant records across ED are kept on paper, electronically, or by 

using a combination of the two, this Handbook discusses record retention 

requirements from the viewpoint of records in electronic format, primarily the 

ED-wide electronic grants management system.

2. The PAM component houses electronic grant files, and some documents are 

automatically stored in these files. For example, GANs and grant applications 

are automatically stored in the PAM grant file for the corresponding grantee.

3. The grants management system is ED’s grants system of record. Program 

offices using and maintaining the PAM grant file as the ED official file allows 

for PAM to serve as ED’s central repository for these files and allows for

information sharing between program offices.

4. Information about PAM and its functionality is available in the online training 

manual.

5. While GMS meets all requirements established by National Archives and 

Records Administration (NARA), in particular those found in Title 36 of the 

C.F.R. (especially 36 C.F.R. part 1236), the interpretations of this Handbook’s 

recordkeeping requirements presume that other electronic systems used for 

creating and maintaining records of the grant process also meet the 

requirements established by NARA.
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Chapter 2: Planning Activities

2.1 Introduction

The discretionary grant planning process includes all activities necessary to set 

up a discretionary grant program. This chapter addresses planning activities 

designed to assist ED in meeting its responsibilities to manage its programs with the 

broadest participation of interested parties in its competitions.

Specifically, this chapter focuses on:

1. Developing a POC spending plan,

2. Establishing schedules for all grant competitions within a POC,

3. Developing regulations and program priorities for grant competitions,

4. Developing performance measures for each program,

5. Evidence Reviews

6. Developing Notices Inviting Applications (NIAs) and application packages for 

each competition; and

7. Distributing application packages.

2.2 Planning Activities

2.2.1 Principal Office Spending Plan

A. Policy

1. POCs develop spending plans to: 1) ensure that ED is fully implementing its 

policies and priorities while making wise investments with its limited 

resources; 2) facilitate the clearance of notices for grant competitions; and

2. POCs submit spending plans for any program funds over which they have 

discretion. Spending plans do not cover programs or activities, such as 

formula grants, for which ED has no funding discretion, because Congress 

specifies how and to which entities funding for these programs and activities 

will be distributed

3. POCs include scheduling and funding information for new grant competitions, 

non- competing continuation (NCC) grant amounts, and new and continuing 

national activities, including those executed through contracts and 

interagency agreements, in their spending plans.
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4. Spending plans total the full amount of discretionary funding available to a 

program and identify and describe each proposed activity that is to be 

supported.

B. Procedures

1. On a yearly basis, the director of the Office of Budget Service (Budget 

Service) issues a memorandum requesting the submission of spending plans.

2. The memorandum includes guidance documents and submission procedures 

to assist with the development of spending plans, and POCs use this 

information when developing their spending plans.

3. POCs submit their spending plans, for review by Budget Service, in 

accordance with the instructions by the due date provided in the spending 

plan memorandum issued by the director of Budget Service.

C. Guidance

1. POCs, in the development of spending plans, should consider the following 

questions:

a. Funding rationale:

b. Why does the program office plan to run a competition this year?

c. Is there a program in which funding down a previous slate is an option?

d. Is a competition required or are there other options for how to use the 

funding? Does ED have flexibility in use of funds that can be considered?

1) Program policy elements:

e. Is rulemaking needed or will requirements be added through a waiver of 

rulemaking?

f. Are there programs in which the administrative or Secretary’s priorities 

could be leveraged?

g. Is it appropriate to include a priority for evidence-based interventions?

h. Is there a need to develop notice of proposed priorities (NPP) and/or 

notice of final priorities (NFP) for any new program?

2. POCs consult with the Office of the Secretary (OS), Budget Service, the 

Office of Planning, Evaluation and Policy Development, Grants Policy Office 

(OPEPD/GPO), and the Office of General Counsel (OGC) when developing 

their spending plans.
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D. Other Pertinent Information – Reserved 

2.2.2 Grant Schedules

A. Policy

1. Program offices develop yearly grant schedules that establish milestones for 

the awarding of new and NCC grants.

2. Individual program grant schedules reflect ED’s goal to award new grants and 

NCC awards in accordance with ED’s priorities and the needs of its 

stakeholders.

B. Procedures

1. Early in every fiscal year, GMPD issues a grant scheduling memorandum to 

POCs that formally initiates the process for entering the fiscal year’s grant 

schedules for all discretionary grant programs into the grants management 

system and provides guidance on entering grant schedule milestones. It also 

includes a list of the data elements that will be tracked by ED to assess 

efficiency in the grant award process.

2. In accordance with the memorandum:

a. Program offices develop a grant schedule for each discretionary grant 

program that contains estimates of the number of new and NCC grants to 

be awarded, the dollar amount approved in the spending plan for the 

grants to be awarded, and the projected completion date for major steps in 

the award process.

b. If applicable, programs with new statutory authority or with new or revised 

funding priorities include the publication dates of regulations or funding 

priorities.

c. Program offices enter grant schedules for all discretionary grant programs 

into the grants management system by the due date stated in the grant 

scheduling memorandum, and update schedules throughout the year as 

needed.

3. The program official of each POC designates a grant scheduling 

representative. The grant scheduling representative is responsible for 

ensuring that grant schedules are entered or deleted from the grants 

management system, when appropriate, and for routinely updating them, if 

needed, based on his/her ongoing review of the data elements identified in 

the scheduling memorandum that are tracked by OPEPD/GPO to assess 

efficiency in the grant award process.
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4. The grant scheduling representative enters individual schedules in the grants 

management system to award grants for:

a. Each program under which new grant or NCC awards are planned in the 

upcoming fiscal year;

b. Applications submitted for funding in the previous fiscal year that are 

being funded in the current fiscal year (see the sections Funding Down 

the Slate and Mishandled Applications); and

c. Congressionally-directed awards, also referred to as earmarks, (see the

Directed Awards section). POCs establish a separate schedule for their 

directed awards for each Assistance Listing (AL) once they become 

aware of directed appropriations and that Congressionally- directed 

awards are to be funded.

5. The grant scheduling representative ensures that subprogram titles are 

consistently and accurately entered and maintained. 

6. When creating a new subprogram title in the subprogram record field, grant 

scheduling representatives:

a. Base subprogram titles on regulatory language or derive them from the 

program statute.

b. Provide the full name of the subprogram title to ensure that the name 

entered clearly identifies the program, and only abbreviate words in long 

titles if the abbreviation can be easily understood.

c. For subprogram titles that contain acronyms or abbreviations, include the 

full subprogram title and the acronym or abbreviation after the full title 

(e.g., Graduate Assistance in Areas of National Need (GAANN)).

C. Guidance

1. In considering milestones for awarding new and NCC grants established in 

the grant scheduling memorandum, program offices should, if feasible, 

endeavor to make new awards earlier than the established milestones.

2. POCs should work to ensure that subprogram data in grant schedules are 

accurately maintained, and that subprogram titles remain consistent from year 

to year unless a statutory, regulatory, or other necessary change requires a 

modification to a title. To do so, the designated grant scheduling 

representative should, when rolling over a prior year subprogram, verify 

existing subprogram data to ensure correct spelling and accuracy of the 

entered title, and make any necessary corrections after the subprogram is 

rolled over.
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D. Other Pertinent Information

1. The Secretary uses information from the grant schedules to monitor the 

status of each POC’s efforts to meet major milestones in the awarding of new 

and NCC grants. ED uses these official data for a variety of internal and 

external purposes.

2.2.3 Assistance Listing Numbers (ALNs) 

A. Policy

1. Federal programs that are newly authorized by Congress must be announced 

in the Federal Assistance Listings on SAM.gov. 

2. For a new program to be assigned an ALN, the program must have funding. 

ALNs are assigned to new programs, not to new competitions.

3. After 3 years of no obligations, a program’s ALN is archived and becomes 

inactive. The numbers cannot be recycled or used by another program. 

However, if the archived program receives funding, the ALN can be 

unarchived for use.

B. Procedures

1. The grant scheduling representative initiates a request for an ALN for newly 

established programs by entering program description information into the 

grants management system. All fields must be completed and should be 

written in plain English, rather than copied from the statute. This information 

will ultimately be posted in SAM.gov. 

2. When the grant scheduling representative submits the request through the 

grants management system, the system notifies the Budget Policy and 

Coordination Division (BPCD) analyst. The BPCD analyst reviews the 

request.

a. If any data are missing or insufficiently documented, the BPCD analyst 

rejects the request in the grants management system, citing a justification, 

and returns it to program offices for completion.

b. If the data are acceptable, the BPCD analyst enters the information into 

the OMB Assistance Listing system, SAM.gov. 

c. It takes an estimated two weeks from the time the data are submitted into 

SAM.gov for OMB to approve the request and assign a new ALN. 

3. After OMB approves and assigns the ALN, the BPCD analyst updates the 

information in the grants management system template with the new ALN, 
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officially approving the request; the system automatically notifies the grant 

scheduling representative of approval.

C. Guidance

1. On a yearly basis, Budget Service reviews all currently active ALNs to verify 

the accuracy of information published on the ALNs website. 

D. Other Pertinent Information

1. The Assistance Listings on SAM.gov is a Federal assistance database that 

incorporates all Federal agency programs that provide financial assistance, 

such as grants, within the United States.

2.2.4 Funding Down the Slate (from previous or same year 

competition) 

A. Policy

1. If program offices receive enough high-quality applications to enable funding 

down the slate (i.e., funding applications from a previous competition), and it 

is not otherwise prohibited in statute or regulations, then funding down the 

slate in a subsequent year is allowable.

2. Program offices notify the public about the possibility of funding down the 

slate, in the future, in the NIA, using the language specified in Chapter J of 

the Regulatory Quality Manual (RQM).

3. Program offices fund additional applications from a competition (i.e., when 

additional funding becomes available later to fund additional applications 

within the competition).

B. Procedures

1. The POC, after reviewing the applications received under the competition, 

and in consultation with the program attorney determines that it has the legal 

authority to fund down the slate and that there are sufficient high-quality 

applications to fund down the slate. Specifically, the following standards apply 

when funding down the slate:

a. Current fiscal year funds are available for projects that can be funded 

under the same program statute, regulations, and priorities established for 

the previous competition.

b. The Principal Officer specifically authorizes using the same slate from a 

previous fiscal year to recommend grant awards for a subsequent fiscal 

year.
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c. A decision to fund down the slate is not inconsistent with congressional 

intent as evidenced by appropriations acts or report language, and the 

applications are of comparable quality to those applications previously 

funded that the program office would have funded them in the prior year if 

they had sufficient funding to do so.

d. The order in which applicants are recommended for funding in the 

subsequent year remains the same as was identified in a prior year slate, 

unless an applicant recommended for funding down the slate in a 

subsequent year is removed because contact with the applicant (see 

Procedure item 3) reveals that the applicant is no longer eligible to receive 

a grant award or no longer has the desire to receive a grant.

2. The grant scheduling representative creates a new discretionary grant 

schedule in the grants management system using the “Funding Down the 

Slate” schedule type. The grants management system automatically uses 

current fiscal year data and reassigns the application’s new or current fiscal 

year PR/Award numbers.

3. The program office, if it did not do so originally, performs a budget review 

(see section Cost Analysis and Budget Review) to determine that cost items 

in an applicant’s proposed Federal and non-Federal budgets are related to 

specific project activities and that those costs are allowable, allocable, and 

reasonable in accordance with the Federal cost principles in 2 C.F.R § 200 

subpart E. The program office removes from the applicant’s budget any 

expenses that are determined to be unallowable.

4. When funding further down a slate of recommended applicants from a prior 

fiscal year, program offices contact applicants to confirm their continued 

eligibility, their capacity to carry out their proposed project as described in 

their application, and to verify and update applicant information. During these 

contacts, programs do not indicate to applicants that they are being 

considered for funding or that they will be funded, but rather, that ED requires 

updated information.

a. If the funds available are insufficient to make a full award to an applicant, 

programs may inquire whether the grantee would accept a reduced award.

b. If an applicant is willing to accept a decreased award amount, the 

applicant submits a revised budget and narrative so that their proposed 

goals and objectives could be accomplished with the reduced award, if 

necessary.

c. Program offices review the revised budget and narrative from the 

applicant to ensure the project remains within the same scope and 

objectives of the original application prior to making the award consistent 
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with the section, Pre-Award Activities. If the submitted revised budget and 

narrative will not be within the scope and objectives of the original 

application, program offices do not make an award to that applicant.

5. Program offices document the Principal Officer’s decision to fund these 

applications in the Grant Funding Slate.

a. Program offices complete the Grant Funding Slate to recommend funding 

applications from the prior competition by adhering to the requirements 

included in the New Slate Memo Template, and include any or all of the 

applicable tables (which are included as components to the ED Grant 

Funding Slate Template), ensuring that the tables are completed in 

accordance with requirements and guidance provided with the table 

templates (see the section Grant Funding Slate - New Grants).

b. Program offices adhere to established procedures for intradepartmental 

review and approval of the Grant Funding Slate prior to making the awards.

c. Documentation reflecting the decision to fund down the slate is included in 

the Competition File that was created for the original competition as well as 

in the Competition File under which applications were funded along with 

the Grant Funding Slate.

C. Guidance

1. Generally, funding down the slate is appropriate for highly competitive 

programs, i.e., those with more high-quality applications than can be funded 

in a given year.

2. Funding down from the same slate in more than one fiscal year is permitted 

wherever the standards specified in the Procedures section are met and the 

following conditions apply:

a. Funding down the slate is not contrary to stated budget policy of the 

Administration.

b. The cost, time, and resources of running a new competition (e.g., peer 

review costs) outweighs the benefit of a new competition.

c. Funding down the slate would not unduly limit the competitive nature of 

the program (i.e., there are potential applicants in year two that would be 

able to submit fundable applications that are not being allowed to do so 

because of our decision).

d. There is no obvious reason to believe that the time lag has created an 

inability of the applicant to successfully carry out the project initially 
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proposed (e.g., the institution is still in good standing, it still can recruit 

participants, the project director has not left the agency, etc.).

3. Program offices consult, as needed, with OS, Budget Service, OPEPD/GPO, 

and the program attorney when considering the applicability of the standards 

established in the Procedures section and the conditions listed for 

consideration in this section.

D. Other Pertinent Information

1. The New Slate Memo Template and its attachments are available at the 

following link: Grant Funding Slate Template. 

2.2.5 Competition Planning and Pre-Clearance Meetings

A. Policy

1. Program offices collaborate with their program attorney, OPEPD/GPO, OS, 

Budget Service, and other offices as appropriate in planning grant 

competitions.

B. Procedures

1. Program offices, prior to developing NIAs, work with OPEPD/GPO, and other 

staff offices, as appropriate for collaborative discussions about the planning 

and strategic direction of upcoming grant program competitions.

2. Program offices’ consideration of the topics and questions under the 

Guidance section below contributes to competition planning and informative 

discussions at pre-clearance meetings.

3. A pre-clearance meeting before the NIA goes into intradepartmental 

clearance may be needed depending on the nature of the program.

C. Guidance

1. Program offices may consider the topics below as early as developing 

spending plans; however, when planning grant competitions, and prior to 

developing NIAs, the following topics and questions should be considered:

a. Purpose and need

b. What are the purpose and goals of the program?

c. Has the field identified a need for the competition or provided relevant 

input to inform its design?
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d. Funding rationale

Why does the program office plan to run a competition this year?

Is ED required to run this competition or are there other options for 

how to use the funding?

Does ED have flexibility in use of funds that can be considered?

e. Program policy elements

1) Requirements:

a) What, if any, statutory requirements (including requirements from 

appropriations language) or existing regulatory requirements must 

be included?

b) Is the program office proposing to add other requirements by going 

through rulemaking, or is the program office establishing 

requirements through a waiver of rulemaking?

2) Priorities:

a) What priorities, if any, are required by statute or appropriations 

language?

b) Which of the Secretary’s priorities could be leveraged under this 

program?

c) Is it appropriate to include a priority for evidence-based 

interventions?

3) Selection criteria:

a) How has past practice informed which selection criteria and factors 

the program office is proposing to use?

b) Which selection criteria and factors are most likely to differentiate 

peer review scores?

c) What kind of evaluation, if any, is appropriate for the proposed 

projects under the program, and how can the evaluation selection 

criteria be crafted to ensure applicants are planning for evaluation? 

When considering this question, the grant size, the mix of required 

and allowable activities, and the state of evidence in the field inform 

whether performance measurement or a rigorous evaluation such 

as experimental/quasi-experimental design studies is appropriate.
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4) Performance measures:

a) What are the program/project performance measures?

b) Are they focused on outcomes or outputs2? 

c) What is the quality of the data and are there opportunities to 

improve the measures?

d) Are the measures designed in a way to allow the data to inform the 

broader education community?

f. Pre-application assistance and outreach

1) How is information shared about the grant opportunity?

2) What steps can ED take to ensure outreach is not limited to those who 

have applied or received grants in the past?

3) What can ED do to make the grant opportunity more approachable for 

new applicants (e.g., pre-application webinars, outreach to broader 

stakeholders in collaboration with OCO, revised application or program 

requirements)?

4) What is enough time for the application period?

a) Program offices when determining how long to keep a competition 

open should consider the size, scope, and requirements in the NIA.

g. Clearance

1) How has the program office partnered with any additional offices to 

design the competition, if applicable?

2) Which offices should review the notice in clearance?

D. Other Pertinent Information - Reserved

2.3 Developing Regulatory Documents

A. Policy

1. Program offices follow the template in the Regulations Quality Manual (RQM) 

when developing NIAs or other applicable documents. The RQM was 

developed by Regulatory Services Division (RSD) and contains a preface 

titled “Principles for Regulating” that describes the principles for and process 

2 Outputs are goods or services produced by the project whereas outcomes are the results of the project.
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of regulating, encourages ED to limit the number of times it regulates, and 

serves as a guide for ED staff involved in drafting or reviewing regulatory 

documents.

2. ED’s policy is to use absolute or competitive preferences priorities for grant 

competitions only where necessary to achieve a desired policy objective. 

Program offices announce these priorities in NIAs in the Federal Register. 

B. Procedures

1. The procedures used to develop a Federal Register document, such as an 

NIA, may vary. In the following table, the first column lists the type of 

document or documents that may need to be prepared to conduct a grant 

competition. The second column identifies the chapter of ED’s RQM that 

contains the appropriate ED template for the style and format for that 

document. The procedures and chapters of the RQM referenced in the table 

on the following page are available at the following link: RQM. 

If you are preparing... see the following chapter of the 

RQM...

A Notice of Proposed Rulemaking 

(NPRM) or final regulations subject 

to the notice and comment 

rulemaking requirements of the 

Administrative Procedure Act

B for NPRMs or D for final 

regulations

Final regulations that waive 

rulemaking

E

A Notice Inviting Applications (NIA) J

A Notice of Proposed Priority or 

Priorities (NPP) for one program

O

A Notice of Final Priority or 

Priorities (NFP) for one program

P

2. If the type of document being prepared does not correspond with an entry in 

the table or there are questions regarding the instructions, contact the 

Regulations Quality Officer or the Regulations Coordinator in RSD for the 

specific program or type of document.

3. Program offices consult with the program attorney for guidance when 

developing Federal Register documents.
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4. Program offices always consult with the program attorney when establishing 

funding priorities (i.e., absolute, competitive preference, and invitational 

priorities) and when determining who should review and score them.

C. Guidance – Reserved

D. Other Pertinent Information

1. The RQM is a clear, concise guide to use in drafting or reviewing applicable 

documents. Because this manual is a working document, OGC may revise it 

in response to new laws, new OMB Federal-wide requirements, and changes 

to ED’s grant award and administration processes.

2.4 Grant Program Performance Measures

A. Policy

1. Program offices ensure the timely collection and analysis of program 

performance data.

a. Program offices collects data on the performance of projects and 

programs administered by ED to inform regular program improvements 

and to provide greater transparency to Congress and members of the 

public about the Department’s management and impact.

b. Budget Service is responsible for coordinating the development, approval, 

and reporting of ED’s performance measures.

B. Procedures

1. Program offices collaborate with Budget Service, OPEPD/GPO, the program 

attorney, and OS as needed in developing the performance measures, and 

Budget Service facilitates OMB approval of the new measures.

2. Program offices report program performance data on all established 

measures at least annually.

C. Guidance

1. ED collects data on the performance of projects and programs administered 

by the Agency to inform regular program improvements and to provide 

greater transparency to Congress and members of the public about ED’s 

management and impact.

2. Budget Service has primary responsibility for coordinating the development, 

approval, and reporting of performance measures.
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3. There are two types of measures that ED may establish for a grant program:

a. Performance measures so that ED can provide information to OMB, in 

accordance with the Government Performance and Results Act of 1993 

(GPRA) and the GPRA Modernization Act of 2010 about its programs 

performance; and

b. Performance measurement requirements for a grant competition under 

EDGAR § 75.110. These may include requirements for performance 

measures, baseline data, or performance targets, or a requirement that 

applicants propose in their applications one or more of their own 

performance measures, baseline data, or performance targets.

4. At pre-application workshops, or other application assistance venues, 

program offices should:

a. Inform participants of the importance of performance when 

conceptualizing the design, implementation, and evaluation of their 

proposed projects.

D. Other Pertinent Information

1. OMB measures the effectiveness of an agency in meeting the goals of its 

programs.

2. The GPRA and the GPRA Modernization Act of 2010 direct Federal 

departments and agencies to improve the effectiveness of their programs by 

engaging in strategic planning, setting outcome-related goals, and measuring 

results against those goals.

2.5 Application Packages and Notices

2.5.1 Application Packages

A. Policy

1. Program offices receive requests for funding under discretionary grant 

competitions through the ED generic application package or through ED 

program- specific application packages.

a. Program offices use the generic application package whenever possible.

2. Program-specific application packages are used when it is necessary to 

collect information or to use forms beyond what the generic application 

package collects (e.g., collecting application information specific to a program 

that cannot be captured in the generic application package, including 
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application package items that are required by a specific program’s statute or 

regulations that are not already included in the generic application package).

B. Procedures

1. Generic Application Package:

a. When program offices use the generic application package (OMB control 

number 1894-0006), the package is used in its entirety. Additional 

program specific forms or other information-gathering requirements 

beyond what the generic application package contains are not added to 

the generic application package.

b. Generic application packages are reviewed by the program attorney 

before being posted for a competition.

c. During the time between triennial OMB approvals for the generic 

application package (see the Other Pertinent Information section below), 

program offices may ask to have a program added to the package 

clearance and have its burden included by submitting a one-page 83-C 

change request form to OMB through the Strategic Collections and 

Clearing (SCC) office. Program offices also use this form to update 

information about a program previously included as part of the initial 

GMPD triennial submission to OMB. Approval from OMB for change 

requests usually requires approximately ten business days.

2. Program-Specific Application Package:

a. Program-specific application packages are cleared through the OMB 

information collection clearance process (1894-0001) before they are 

made available to potential applicants.

b. Proposed program-specific application packages are reviewed by the 

program attorney and Budget Service prior to any internal clearance or 

clearance with OMB.

c. Program offices work closely with SCC during the development process, 

to ensure compliance with information collection requirements, and follow 

the procedure established by SCC to clear the program-specific 

application package. The ICR will receive its separate OMB control 

number upon OMB approval.

d. Program-specific application packages are consistent with ED policies and 

applicable statutory or regulatory requirements (e.g., program-specific 

application packages include the scoring rubrics that will be used to review 

and score applications, if applicable (see the Scoring Rubrics section). 
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3. Generic and program-specific application packages and their associated NIAs 

refer applicants to ED’s Common Instructions for Applicants to Department of 

Education Discretionary Grant Programs (Common Instructions), available at: 

Federal Register Vol. 86 FR 73264, to inform applicants of the requirement to 

have a Unique Entity Identifier (UEI) number and Taxpayer Identification 

Number (TIN) registered with the System for Award Management (SAM), the 

U.S. Federal Government’s primary registrant database, in order to receive 

payments and do business with ED.

4. Application packages are posted for access by potential applicants in 

Grants.gov. Before application packages are posted in Grants.gov, the 

associated grant competitions are announced in NIAs in the Federal Register, 

as addressed in the section Notices Inviting Applications (NIA). 

C. Guidance

1. If an application package is using only standard Department or Federal-wide 

grant applications forms that have already been approved by OMB, and 

selection criteria from the following sources (including combinations of the 

following sources)3, the program office may use the generic application 

package:

a. Selection criteria from 34 C.F.R. 75.210. 

b. Selection criteria based on statutory provisions, as authorized under 34 

C.F.R. 75.209. 

1) Example of a selection criterion based on a statutorily required use of 

funds (statutory language is underlined (Section 6133(e)(1)(B) of the 

Elementary and Secondary Education Act of 1965): The Secretary will 

evaluate the quality of the applicant’s plan to provide professional 

development for teachers and, as appropriate, staff and administrators 

to strengthen the overall language and academic goals of the school 

that will be served by the grant program.

2) This is an example of a selection criterion based on a statutory 

allowable use, but under 34 C.F.R. 75.209, a program could create 

selection criteria from other statutory language including application

requirements, program purposes, or other pre-award and post-award 

conditions.

3 In general, an application package that uses application requirements would or would not be able to use 

the generic clearance process under the same conditions as set out for application packages using 

various types of selection criteria. Whether the use of application requirements would implicate the 

Paperwork Reduction Act (and, therefore, the generic clearance process) needs to be determined on a 

case-by-case basis that considers if the application requirements introduce any new, substantive 

elements that have not been previously approved by OMB. 
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c. Selection criteria based on regulatory provisions, and there is an ICR 

accompanying that regulatory provision that has undergone notice and 

comment, as authorized under 34 C.F.R. 75.209. 

1) Example of a selection criterion based on a requirement from the 

C.F.R. (regulatory requirement is underlined (34 C.F.R. 263.11(a)): 

The Secretary will consider the quality of the applicant’s plan to, prior 

to providing funds or services to a participant, conduct a payback 

meeting with the participant to explain the costs of training and 

payback responsibilities following the training.

2) This is an example of a selection criterion based on a regulatory 

allowable use of funds, but under 34 C.F.R. 75.209, a program could 

create selection criteria from other regulatory language including 

application requirements, program purposes, or other pre-award and 

post-award conditions.

3) NOTE: The generic process is available for application packages 

using recently established regulatory provisions 4 that are the basis of 

the selection criteria only where there was a separate ICR 

accompanying the recently established regulations that was submitted 

to OMB simultaneously with the proposed rule and the ICR has 

undergone its own notice and comment and OMB has approved the 

ICR before it is used as a selection criterion. 

d. Selection criteria from regulatory provisions and the accompanying ICR 

has undergone notice and comment 

1) Example: 34 C.F.R. 263.6(a): (a) Need for project. In determining the 

need for the proposed project, the Secretary considers one or more of 

the following:

a) The extent to which the proposed project will prepare personnel in 

specific fields in which shortages have been demonstrated through 

a job market analysis.

b) NOTE: most programs do not have regulatory provisions (i.e., 

provisions in the C.F.R.) containing selection criteria.

c) NOTE: The generic process is available for application packages 

using recently established selection criteria from regulatory 

provisions only where the separate ICR accompanying the recently 

established regulations has been submitted to OMB simultaneously 

with the proposed rule and the ICR has undergone its own notice 

4 A regulatory provision is “recently established” where it has not been used in a discretionary grant 

competition previously.
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and comment and OMB has approved the ICR before it is used as 

a selection criterion.

e. Selection criteria that have been developed through a Notice of Final 

Priorities (NFP) and the accompanying ICR has undergone notice and 

comment.

1) Example: Final Priorities, Requirements, Definitions, and Selection 

Criteria-Expanding Opportunity Through Quality Charter Schools 

Program; Grants to Charter Management Organizations for the 

Replication and Expansion of High-Quality Charter Schools

2) NOTE: The generic process is available for application packages 

using recently established selection criteria 5 developed through an

NFP only where there was a separate ICR accompanying the recently 

established NFP that was submitted to OMB simultaneously with the 

NPP and the ICR has undergone its own notice and comment and 

OMB has approved the ICR before it is used as a selection criterion. 

f. Some programs have program-specific priorities, application 

requirements, or other types of requirements that are established through 

the rulemaking process or in the notice inviting applications based on 

statute or regulations. If these priorities or requirements do not require a 

program-specific form for applicants to comply, a program office may use 

the generic application package. This is true regardless of the source of 

authority for these requirements (e.g., requirements based on statute or 

regulations).

1) Example: A notice inviting applications using selection criteria from the 

list above includes a requirement based on statutory language that 

applicants must assure to meeting certain requirements but does not 

need a particular form for applicants to meet this requirement 

(applicants determine how to include this “assurance” in their individual 

applications).

2. Application package involving selection criteria that have been developed 

using a waiver of rulemaking (“GEPA waiver”): When the Department runs 

the first competition under a new or substantially revised program authority, 

section 437(d)(1) of the General Education Provisions Act (GEPA) allows the 

Department to waive the notice-and-comment rulemaking requirements that 

normally apply. Programs that establish program-specific selection criteria 

through this process may not use the generic application package, and 

instead must go through the streamlined discretionary grants clearance 

process. This involves a 60-day clearance process in which OMB will review 

5 A regulatory provision is “recently established” where it has not been used in a discretionary grant 

competition previously.
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the program-specific form in conjunction with the accompanying notice. 

Please consult with the Strategic Collections and Clearance (SCC) office for 

more information about clearance procedures.

a. If a competition uses the GEPA waiver to establish priorities or 

requirements that apply to the competition, but not selection criteria (and 

instead uses only selection criteria from section 1 above), and these 

program-specific priorities or requirements do not involve program-specific 

forms, it may use the generic application package.

1) Example: A notice inviting applications uses the GEPA waiver to 

establish an application requirement, but this requirement does not 

require the use of a program-specific form. The notice inviting 

applications uses only selection criteria from 34 C.F.R. 75.210. This 

program may use the generic application package.

b. However, if the selection criteria established pursuant to a GEPA waiver 

do not require the collection of additional information from applicants 

because the data are collected under a separate approved OMB ICR, the 

program may use the generic application (unless these criteria require the 

use of a program-specific form) because these criteria do not introduce 

any new burden on applicants. 

1) Example: A notice inviting applications from institutions of higher 

education uses the GEPA waiver to establish new selection criteria to 

evaluate applications based on “Need” where “Need” is assessed 

based on the percentage of students enrolled at the institutions of 

higher education who are Pell recipients. If the Department plans to 

use the data available in the NCES IPEDS data collection to apply 

these criteria, then the new criteria do not introduce any new burden or 

require the collection of any new information. Consequently, this 

program can use the generic application.

3. Since program-specific application packages can potentially require much 

time and effort to prepare and clear through OMB for information collection, 

programs should begin working on application packages early in the process 

of planning for grant competitions.

4. Program offices should make every effort to distribute application packages to 

as many potential applicants as possible by placing application packages on 

the ED website and Grants.gov, or any other medium that can make 

applications widely available. However, regardless of where the package is 

made available, all applicants will follow the submission instructions noted in 

the Common Instructions.
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5. Program offices using a previously approved program-specific application 

package in their competition should actively monitor the renewal/expiration 

dates of their application package to ensure that their approval will not expire 

prior to the time of the competition.

D. Other Pertinent Information

1. One of the chief advantages the generic application package offers to 

program offices is that it has already received OMB approval and does not 

require POCs to obtain approval independently.

a. GMPD, once every three years, submits to OMB on behalf of ED, the 

“umbrella” request for clearance of the package, which includes 

paperwork burden data for all programs that have asked to be included as 

of the date of submission.

b. Once OMB approves the package for the next three years, covered 

programs do not need to do anything else, unless information about a 

program or its burden data substantially changes.

2. The generic application package is also cleared for the purpose of using 

statutory, regulatory (selection criteria that program offices have created 

through rulemaking for a specific program), or EDGAR selection criteria, thus, 

making it of particular benefit to programs that do not have established 

criteria, and that can achieve their competition objectives by using the general 

EDGAR selection criteria.

3. The generic application package contains a collection of required forms and 

documents commonly used by many programs for their discretionary grant 

competitions. The generic application package and required information that 

is included in program-specific application packages is available at the 

following link: Grant Application Toolkit. 

4. The SCC staff manages ED’s information collection process. A list of SCC 

contacts, policy and guidance on the information collection process and the 

Paperwork Reduction Act (PRA) of 1995, as well as, the “Guide to the 

Information Clearance Process” are available at the following link: Information 

Collection. 
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2.5.2 Changes to an Approved Program-Specific Application Package

A. Policy

1. Program offices consult with their Information Collection Coordinator (ICC) or 

SCC liaison before making changes to an OMB approved application 

package.

B. Procedures

1. Program offices seek an Information Collection Clearance from OMB if 

changes are needed to an approved application package, when the changes 

are substantive or non-substantive in nature, and there are possible reporting 

burden adjustments associated with changes to an approved application 

package.

a. A substantive change (or revision) is a change that impacts the application 

requirements, the number of respondents (applicants) due to adding a 

new respondent group/entity, or burden hours. These types of changes 

require the submission of an information collection request to SCC.

b. A non-substantive change requires an OMB 83-C form be submitted to 

SCC with the modified application document and a detailed explanation of 

the changes. Before making a non-substantive change to an approved 

application, programs consult with SCC who determines if the change is 

substantive, such that it impacts the application requirements, the number 

of respondents (applicants) or burden hours and provides advice on how 

to proceed.

c. Non-substantive changes require OMB approval to keep the official record 

current, but do not require a full information collection request. Rather, 

program offices complete an OMB 83-C form and provide the modified 

document with a detailed explanation of the changes.

d. Non-substantive changes include clarifying language that do not impose 

new data elements or burden, date changes and editing corrections that 

are fixes and are not considered substantive (no new burden), or minor 

changes that do not impact applicant burden or application submission 

requirements. Note that if program offices only change the dates for the 

subsequent year or fixes minor typos, they will not require an OMB 83-C 

request.

2. Changes to a grant application package posted to Grants.gov with an error:

a. Program offices determine how the PRA process impacts correction of the 

error, to decide how best to correct the error. Minor errors, such as typos 

or date changes, do not need to go through the PRA process.
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b. For application packages with non-substantive errors, a correction may be 

made without SCC involvement, and it should be made in Grants.gov

when possible. For example, an incorrect funding dollar amount can be 

corrected immediately via Grants.gov and without SCC involvement.

3. Changes to an approved grant application package:

a. For application packages that require substantive changes, program 

offices consult with SCC to confirm that OMB Information Clearance 

Collection is required and follow SCC guidance to complete an information 

collection request. All substantive changes are resubmitted to SCC for full 

information collection clearance. An OMB 83-C form cannot be used for 

substantive changes.

b. For application packages that require non-substantive changes, SCC 

processes and sends an OMB 83-C form from the program office, with an 

explanation for the detailed changes, and latest draft application package 

to OMB for approval.

4. Requests with substantive changes to application packages go through a 30-

day comment period and another 30 days for OMB’s review and approval. If 

the grant does not fit the generic clearance, OMB requires a 30-day comment 

period notice for all other discretionary grants under the streamlined 

clearance process (OMB waived the 60-day comment period notice) but OMB 

can take a full 60 days to review/approve the request. Generic grants do not 

require comment period notices once approved under the generic clearance 

vehicle via an OMB 83-C request; subsequent OMB 83-Cs are not required if 

they continue to fit under the generic clearance.

5. OMB approves the latest draft application package prior to it being made 

available to the public, which can take from 10-20 business days once an 

OMB 83-C is submitted to OMB.

6. Program offices will notify applicants and Grants.gov of the subsequent 

revision.

7. In cases where there is an inconsistency between the NIA and the application 

package, the NIA must be followed, as opposed to materials in the application 

package. If the NIA is incorrect, a correction notice in the Federal Register is 

issued.
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C. Guidance – Reserved

D. Other Pertinent Information

1. The SCC contacts, policy and guidance on the information collection process 

and the PRA, as well as SCC’s “Guide to the Information Clearance Process,” 

are available at the following link: Information Collection 

2.5.3 Notifying Applicants of ED’s Indirect Cost Requirements

A. Policy

1. Program offices inform applicants, in the application package, about the 

program’s policy for reimbursing grantees for indirect costs that they incur as 

they undertake their projects.

2. Program offices include, in the application package, the appropriate indirect 

cost guidance for the grant program for applicants to understand the indirect 

cost reimbursement requirements under the program funding the competition, 

and to be able to estimate indirect costs more accurately in their application 

budget.

3. For programs that do not provide indirect cost reimbursement under awards 

(No Reimbursement), applicants are made aware that unreimbursed indirect 

costs under grants of the program may not be charged as direct cost items in 

the same award, used to satisfy cost sharing or matching requirements, or 

charged to another Federal award.

4. For detailed information about indirect cost reimbursement requirements and 

other indirect cost related information and requirements, see the following 

sections: Indirect Costs - General, Indirect Costs – Temporary Rates Plus 

Negotiated Agreements, Indirect Costs – Temporary Rates – Retroactive 

Recovery, Indirect Costs – De Minimis Rate – No Negotiation, Indirect Costs 

– Training Grants, Indirect Costs – Restricted Rate Programs. 

B. Procedures

1. Program offices include the insert titled, “Program Application Indirect Cost 

Instructions” in the grant competition application package.

C. Guidance – Reserved

D. Other Pertinent Information

1. Program offices access the indirect cost application package guidance insert 

titled, “Program Application Indirect Cost Instructions” at the following link: 

Grant Application Toolkit. 
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2. 

2.5.4 Sources of Funding Information

A. Policy

1. Program offices, in accordance with the requirements in 2 C.F.R. § 200.203, 

and to provide public notice of Federal financial assistance programs, publish, 

in various media, information about the grant programs and competitions 

under which ED expects to invite applications for new grant or cooperative 

agreement awards.

B. Procedures

1. Programs offices facilitate the posting of information for the public’s benefit 

about the grant programs and competitions for new grant or cooperative 

agreement awards on ED.gov, Grants.gov, and on ED’s Grants Forecast

webpages.

C. Guidance – Reserved

D. Other Pertinent Information

1. Potential applicants can obtain information about grant programs and 

competitions through:

a. The Assistance Listings on SAM.gov – The Assistance Listings is a 

Federal assistance database that incorporates all Federal agency 

programs that provide financial assistance, such as grants, within the 

United States.

b. ED.gov – Potential applicants can access information on discretionary 

grant funding by accessing ED’s website and selecting the “Grants” link.

c. Grants.gov – The Federal government maintains a portal for electronic 

grant applications at Grants.gov. ED is committed to using Grants.gov for 

all its grant competitions. This portal has a feature called “Search Grants” 

that prospective applicants can use to locate grant opportunities from all 

Federal grant making agencies, and which also leads to the NIA published 

for a competition. ED currently posts notice of all its grant competitions on 

Grants.gov. 

d. ED’s Grants Forecast – The forecast is intended to assist potential 

applicants in planning projects and activities for upcoming ED 

competitions. The forecast is advisory only, and not an official NIA. It 

provides actual or estimated deadline dates for the submission of 
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applications and the names and telephone numbers of persons to contact 

for information about a specific program.

2.5.5 Evidence Reviews

A. Policy

1. Program offices conduct grant competitions that measure the extent to which 

applicants address any of the four tiers of evidence established in EDGAR for 

grant programs that provide funding based on how well grant applications 

contain evidence demonstrating the effectiveness of their proposed grant 

projects.

a. The four tiers of evidence (i.e., Evidence that Demonstrate a Rationale, 

Promising Evidence, Moderate Evidence, and Strong Evidence) range 

from a Logic Model informed by relevant research or evaluation findings, 

for those program offices that aim to fund projects in the design and 

development stage that do not yet have an established evidence base 

demonstrating effectiveness, to projects that are supported by Moderate 

Evidence or Strong Evidence.

2. Program office work with the Institute of Education Sciences (IES) as 

established in the Procedures section below when required by the listed 

procedure.

3. Program offices specifically work with the What Works Clearinghouse

(WWC), which was established by IES for the purpose of using rigorous and 

relevant research, evaluation, and statistics to inform efforts to improve the 

nation’s education system.

a. The WWC, as it relates to grant competitions, uses its evidence standards 

to review, rate, and summarize original studies that focus on the 

effectiveness of education interventions (programs, policies, practices, or 

products) that are meant to improve education outcomes, including 

outcomes for students and teachers.

b. Under EDGAR, studies must meet WWC evidence standards as well as 

additional requirements to provide Moderate Evidence or Strong 

Evidence.

B. Procedures

1. Using evidence as an “Entry Requirement.”

a. Planning the Competition: During ED’s annual spending plan process, 

program offices work with the OPEPD/GPO, Budget Service and IES to 
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determine whether it is appropriate to use one (or more than one) of the 

evidence tiers in their competitions.

1) In general, the WWC will only assess citations as providing Moderate 

Evidence or Strong Evidence, not Promising Evidence or Evidence that 

Demonstrates a Rationale.

2) Any assessments of lower tiers of evidence may require program 

offices to form panels of external reviewers familiar with education 

research and effectiveness studies.

3) IES can provide a list of WWC-certified reviewers who are qualified to 

assess studies for Promising Evidence, which does not require a full 

WWC review, and may be able to suggest other reviewers with a 

research background appropriate for reviewing evidence submitted 

with applications.

b. Designing the Review: When including a priority in their competition for 

Strong Evidence, Moderate Evidence, or Promising Evidence, program 

offices describe in the ATRP the review process for determining whether 

an application is supported by the designated tier of evidence. The 

process discusses how program offices will document that each 

application was reviewed as well as the assessment and recommendation 

from each review.

1) For priorities for projects supported by Strong Evidence or Moderate 

Evidence, program offices work with IES/WWC to conduct the review.

2) For priorities for projects supported by Promising Evidence, program 

offices may use external peer reviewers with appropriate expertise to 

conduct the review.

3) If the program is using an absolute priority for projects supported by 

Promising Evidence, ED staff make the final decision on whether each 

application meets the absolute priority.

c. Timing the Review: Program offices build an estimate of costs into the 

amount allowed for peer review as well as estimate the amount of time 

needed to conduct an evidence-based competition.

1) IES asks program offices to encourage applicants, in their preapplication assistance efforts, to use practice guides, intervention 

reports, or previously reviewed studies in support of their application so 

that programs do not incur new expenses since each new study that 

needs to be reviewed currently costs a little more than $3000.
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2) Program offices use the table titled, Process for Conducting Reviews 

of Evidence Submitted as an ‘Entry Requirement’ as a guide to assist 

with this process available at Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process.

3) Depending on the tier of evidence being used, program offices may be 

able to incorporate the evidence review into the peer review process. 

However, if using Moderate Evidence or Strong Evidence, program 

offices coordinate with IES about plans for those reviews, as described 

in the Guidance section (1)(b) below. This is a necessary step due to 

the complexity of the definitions for Moderate Evidence and Strong 

Evidence.

2. Program offices’ grant competitions ask applicants to submit evidence of 

effectiveness in support of their proposed projects --- Reviewing evidence as 

an “Entry Requirement”:

a. Program offices use the Evidence Form in the application package to 

identify the studies cited by applicants that are to be reviewed. For 

programs using a priority for projects supported by Strong Evidence or 

Moderate Evidence they coordinate the review of those citations with IES 

by providing the citations in a consistent Excel format for use by the 

WWC.

b. Program offices using Moderate Evidence, Strong Evidence or Promising 

Evidence as an entry requirement include language in the NIA defining the 

evidence definitions being used and specifying the maximum6 number of 

study citations an applicant may include in its application for the evidence 

review. IES and OPEPD/GPO can comment, prior to the publication of 

the NIA, on the evidence-related terms proposed for that document.

c. For competitions with a high volume of applicants, programs using 

Moderate Evidence or Strong Evidence only request WWC evidence 

reviews for studies cited in highly rated applications after the completion of 

peer review.

d. The results of the WWC review of each cited study are summarized in 

Word documents known as evidence templates. Program offices should 

agree with the WWC team on the format of those templates, which should 

correspond with the evidence definitions in the NIA.

1) As part of the WWC review, IES provides information to the program 

offices about the intervention, population, and setting for each study 

citation that was reviewed, and program offices, often taking into 

6 3 Program offices may specify a maximum number of study citations allowed since this is a procedural 

matter which does not require rulemaking under the Administrative Procedures Act (APA).
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account the conclusions of panelists reviewing applications, use that 

information to make a determination about the relevance of the 

intervention, population, and setting of the study compared to what the 

applicant is proposing in the application.

2) It is important to note that IES only evaluates whether a study citation 

meets the strength of evidence requirements for Moderate Evidence or 

Strong Evidence; program offices ultimately assess whether the study 

citation is relevant to the proposed project. Both the standards for rigor 

and relevance must be met in order to determine whether an 

application meets the evidence standard established for the 

competition.

e. Promising evidence is reviewed via a peer review process, using 

reviewers with a research background appropriate for reviewing evidence 

submitted with applications.

1) Program offices consult with IES and OPEPD/GPO, and other grants’ 

program staff to create an evidence template that meets their 

program’s needs based on the evidence definitions in the NIA.

2) Evidence peer reviewers will review each citation provided on the 

evidence form in the application to review whether it meets the 

requirements for promising evidence.

3) If program offices need help retrieving a citation listed by a grant 

application, then the specific part of IES that would help is the National 

Library of Education.

4) Evidence peer reviewers can also provide feedback on the relevance 

of the citation to the proposed project, but program offices are 

ultimately responsible for assessing whether the citation is relevant to 

the proposed project.

5) Both the standards for rigor and relevance must be met in order to 

determine whether an application meets the evidence standard 

established for the competition.

3. Using evidence as an “Exit Requirement”:

a. When deciding to use selection factors under EDGAR § 75.210(h) (Quality 

of the Project Evaluation) to encourage applicants to propose methods of 

evaluation that would produce evidence about their project’s effectiveness, 

program offices, in the NIA for a grant competition, communicate the 

program office’s expectations that applicants will address how they will 

make the findings from their project evaluations publicly available. 

Consultation with IES is desirable to assess the feasibility of expecting 
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projects to plan evaluations to build Promising Evidence or meet WWC 

evidence standards. At a minimum, IES should be asked to comment on 

the evaluation-related language in the NIA prior to it being published.

b. Program offices coordinate with IES to ensure the reviewers selected to 

assess a project’s evaluation have the appropriate qualifications. Program 

offices also coordinate in advance with IES if IES is being asked to play a 

role in providing evaluation technical assistance (TA) to applicants or to 

grantees, and especially if IES is being requested to assist with a contract 

to provide TA to project evaluators on the design and implementation of 

rigorous impact evaluations.

C. Guidance

1. Using Evidence as an “Entry Requirement”:

a. Prior to determining whether to use evidence in a competition, program 

offices should determine the current state of evidence in the field for the 

projects that the program intends to fund, and whether existing research 

meets a particular tier of evidence defined in EDGAR. One method 

program offices might use to make this determination is a literature review 

in consultation with IES and OPEPD/GPO, examining evidence that 

project components that can be supported under the program have 

positive effects on relevant outcomes. Absent relevant studies already 

reviewed by the WWC that meet the EDGAR definitions of Moderate 

Evidence or Strong Evidence, program offices should consider using a 

lower tier of evidence, such as Evidence that Demonstrates a Rationale (if 

no studies with relevant statistically significant findings are found) or 

Promising Evidence.

b. When using Moderate Evidence or Strong Evidence, program offices 

should coordinate with the WWC team at IES as early as possible in the 

planning process about the number of studies for which they are likely to 

need a WWC review, the availability of program funds for those reviews, 

and how much time will be required to award the task order to support the 

reviews and complete those reviews (also, see Procedures item 1.c. 

above). In general, the specification of the evidence review work with IES, 

the program office, and Budget Service needs to occur at least six months 

prior to the time when the results of those reviews are needed. IES should 

review and contribute materials for any webinars describing the evidence 

definitions and evidence review process to potential grant applicants. 

Funding for the evidence reviews needs to be provided at least four 

months prior to the time when the reviews need to be completed. Study 

citations should be provided to the WWC team at least two months prior to 

the time when the evidence reviews need to be completed.
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2. Reviewing Evidence as an “Entry Requirement”:

a. When recommending, in the NIA, the number of study citations an 

applicant may include in its application for the evidence review (see 

Procedures item 2.b. above), IES suggests a limit of four study citations 

for Strong Evidence and two study citations for Moderate Evidence.

b. Additionally, IES recommends that program offices using Promising 

Evidence, Strong Evidence and Moderate Evidence ask applicants to 

specify the findings within the citations that the applicants are requesting 

be considered as Promising Evidence, Strong Evidence, and Moderate 

Evidence including page number(s) of specific tables, if applicable. When 

citing WWC intervention reports, as allowed under EDGAR, applicants 

should cite findings of the effectiveness of the intervention outcome 

domains relevant to their project. When citing WWC Practice Guides, as 

also allowed under EDGAR, applicants should cite specific practice 

recommendations, since the strength of the evidence base may vary 

across recommendations in the same guide

3. Building Evidence as an “Exit Requirement”:

a. Program offices, in consultation with IES and OPEPD/GPO, should 

consider using selection factors under EDGAR § 75.210(h) (Quality of the 

Project Evaluation) to encourage applicants to propose methods of 

evaluation that would produce evidence about the project’s effectiveness 

that would meet the WWC evidence standards with or without reservations 

or yield Promising Evidence. By using these factors, program offices can 

encourage applicants to propose project evaluations that, if wellimplemented, could be cited as sources of Promising Evidence, Moderate 

Evidence, or Strong Evidence in the future.

D. Other Pertinent Information

1. The sections in EDGAR that are specific to evidence of effectiveness include:

a. EDGAR § 75.226, which authorizes program offices to consider the 

effectiveness of projects under a priority that could be used as either an 

absolute or competitive preference priority.

b. EDGAR § 75.210© (Quality of the Project Design), which establishes 

selection criteria that would allow the Secretary to consider the extent to 

which the proposed project is supported by Promising Evidence or 

Demonstrates a Rationale.

c. EDGAR § 75.210(h) (Quality of the Project Evaluation), which includes 

five factors to assess the extent to which the proposed project evaluation 

would produce evidence about the project’s effectiveness. Two of these 
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selection factors would link to the WWC evidence standards and promote 

the use of the strongest possible study designs for estimating a project’s 

impact. The other three selection factors would allow the Secretary to 

consider evaluation methods that will produce data on a project’s 

Promising Evidence, performance on relevant outcomes, and fidelity of 

implementation.

d. EDGAR § 77.1, in which the definitions for the four tiers of evidence, and 

other evidence-related definitions, are established to ensure consistent 

understanding of the terms used in the selection factors and priority.

2.5.6 Notices Inviting Applications (NIAs)

A. Policy

1. Program offices, after approval is granted through the RSD clearance 

process, publish an NIA in the Federal Register to announce and invite grant 

application submissions for one or more competitions.

2. Program offices’ NIAs reference ED’s Common Instructions, a centralized and 

up to date set of instructions for applying to ED’s discretionary grant 

programs, which informs applicants of:

a. The requirements to register in SAM and to have an active UEI and TIN, 

since these are required in order to do business with ED;

b. Application submission requirements for Grants.gov, and requirements for 

requesting an extension when Grants.gov is not available due to technical 

issues; and

c. Requirements for paper submissions when electronic submissions are not 

possible because the applicants do not have access to the internet or the 

necessary technology.

3. Program offices’ NIAs also include the following as required by Chapter J of 

the RQM and 2 C.F.R. Part 200: 

a. The selection criteria and process to be used to evaluate applications (see 

2 C.F.R. § 200.204);

b. A description of ED’s criteria for evaluating applicants’ risks (see 2 C.F.R. 

§ 200.206);

c. The FAPIIS review disclosures to inform applicants that ED reviews and 

considers information available about the applicants in FAPIIS before 

making awards that will, over the applicants’ performance period, exceed 

the simplified acquisition threshold addressed in OMB Memorandum M-
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18-18, “Implementing Statutory Changes to the Micro-Purchase and the 

Simplified Acquisition Thresholds for Financial Assistance” available at: 

OMB Memoranda; and

d. Other required information per Chapter J of the RQM. 

4. After approval is granted through the RSD clearance process, Program 

offices’ NIAs are approved through the SCC clearance process and are sent 

to the Federal Register for publication by SCC.

a. OMB reviews NIAs that are deemed significant via the OGC/RSD process. 

RSD coordinates this review. Under the Paperwork Reduction Act (PRA) 

office for information collections review (a separate process), finalized 

drafts of the NIA are required to be part of the grant application if the POC 

is seeking approval through the generic or discretionary grant clearances.

5. Executive Order (EO) 12372, as implemented by EDGAR C.F.R. part 79, 

establishes a system for State and local governmental review of proposed 

Federal assistance applications. Applicants contact their State single point of 

contact (SPOC) as early as possible to alert the SPOC to prospective 

applications and to receive instructions on the State’s process. 

a. The current SPOC list, Intergovernmental Review SPOC List is available 

on the White House website. States that are not listed have chosen not to 

participate in the intergovernmental review process. If an applicant is 

located within a State that has chosen not to participate, no further action 

is required under the EO.

b. The applicant sends its application to the State SPOC in a timely manner 

for the SPOC to have enough time to review and provide any comments to 

ED’s contact identified in the application package before the end of the 

application comment period. Under EO 12372, the application comment 

period is 60 days for new and competitive awards and 30 days for NCC 

awards, unless the statute requires a longer review. The deadline for 

intergovernmental review is published in the NIA. Before making a funding 

decision, ED considers any comments made by the SPOC.

c. A waiver of the standard 60-day period for new and competitive awards is 

possible when the full State application comment period would affect the 

period of time applicants have to prepare their applications (e.g., if the 

standard 60- day application preparation comment period plus the full 

State review period would delay awards past ED’s deadline for making 

awards). The Office of Communications and Outreach (OCO) may grant a 

partial or complete waiver of the standard 60-day period when requested 

by the program. The application comment period should not be less than 

30 days.
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B. Procedures

1. Program offices, before preparing an NIA, consult with their liaison in SCC to 

determine what other types of documents might be needed for a particular 

competition (see the Developing Regulatory Documents section).

a. Before publishing an NIA, program offices may first need to publish in the 

Federal Register another document or documents, such as an NPRM, 

final regulations, a notice proposing one or more funding priorities, 

selection criteria or other requirements, or a notice announcing one or 

more final priorities, selection criteria, or other requirements, if applicable.

2. Program offices, during the drafting process, consult with their program 

attorney for guidance regarding the NIA’s legal content related to the program 

statute and regulations, and when seeking to issue an NIA using the waiver of 

rulemaking provided in GEPA for “the first grant competition under a new or 

substantially revised program authority.”7

3. When OCO waives the intergovernmental review comment period in 

response to requests from programs, the justification for the waiver or for 

shortening the deadline is placed in the grant competition file.

C. Guidance

1. To facilitate the clearance of an NIA through the RSD clearance process, 

programs are advised to take the following steps:

a. Keep schedules current in the grants management system to enable RSD

to plan its clearance schedule;

b. Consult with RSD in advance on format issues or questions that arise 

while preparing the notice, especially if there is a need to deviate from the 

standard format in Chapter J of the RQM; 

c. Ensure that the notice includes the GPRA program performance 

measures, any EDGAR § 75.110 performance measures, and instructions 

to applicants on project evaluation requirements; and

d. Include a cover memorandum describing changes from previous notices 

for the program.

2. Program offices should maximize the number of days applicants have to 

submit applications (i.e., days between posting the NIA and the application 

deadline). The recommendations are a minimum of 60 days for new programs 

and a minimum of 45 days for existing programs. However, under exigent 

7 4 20 U.S.C. §1232(d)(1).
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circumstances a period as little as 30 days is permissible. Programs should 

consider longer periods for more complicated competitions.

D. Other Pertinent Information

1. Once an NIA is cleared and approved, it is published in the Federal Register

to inform potential applicants of a new grant competition (see EDGAR § 

75.100).

2. NIAs provide basic program and fiscal information on each competition, the 

type of award (e.g., discretionary or cooperative agreement, etc.), information 

about when and where potential applicants may obtain applications, the 

deadlines for when applications must be submitted to ED and identify 

estimates regarding the number and amount of awards (See EDGAR §§ 

75.100, 75.101 and 75.201).

3. The required FAPIIS review disclosure, referenced in the Policy section 

above, informs applicants of the following:

a. ED will review and consider available information about the applicants in 

FAPIIS before making awards that will, over the applicants’ performance 

period, exceed the simplified acquisition threshold addressed in OMB 

Memorandum M-18-18, “Implementing Statutory Changes to the MicroPurchase and the Simplified Acquisition Thresholds for Financial 

Assistance” available at OMB Memoranda. This threshold is periodically 

adjusted for inflation in accordance with 41 U.S.C. § 1908, “Inflation 

Adjustment of Acquisition-Related Dollar Thresholds.”

b. If a grant is awarded that may make available more than $500,000 in 

Federal funds over the project period of the grant, per Appendix XII, the 

grantee is informed of the reporting requirements in 2 C.F.R. Part 200. 

Appendix XII applies if the total value of a grantee’s currently active 

grants, cooperative agreements, and procurement contracts from all 

agencies of the Federal government exceed $10,000,000. If Appendix XII 

applies to a grantee, it is required to report certain integrity information 

about itself to FAPIIS on a semi- annual basis.

c. Applicants may review information about themselves in FAPIIS that was 

entered by a Federal agency and may provide comments on that 

information. This disclosure also communicates that ED will consider 

comments by an applicant about its FAPIIS information when making 

judgments about an applicant’s integrity, business ethics, and record of 

performance under Federal grants (see Appendix I of 2 C.F.R. Part 200).

4. The FAPIIS disclosures that are included in all NIAs are provided in Chapter J 

of the RQM. 
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2.5.7 Communication with the Public about Competitions

A. Policy

1. Program offices protect the integrity of the competitive process by ensuring 

that all application guidance is disseminated widely and publicly and does not

inadvertently provide advantage or opportunity to any one potential applicant 

or group of applicants (such as those that have previously received awards).

2. Program offices preserve the deliberative process by ensuring that 

preliminary decisions are not disseminated publicly.

3. Before the deadline date of a competition, program offices’ communications 

are limited to the information in the NIA or publicly released through, for 

example, program application frequently asked questions (FAQs), program 

blog, or posting on a program website.

4. All written FAQs, application assistance information, and guidance must be 

reviewed by the program attorney before being shared publicly.

a. Unless specifically marked otherwise, draft versions of FAQs, application 

assistance information, guidance, and documents for publication in the 

Federal Register are considered Controlled, Unclassified Information and 

are not for distribution outside ED. Program offices distribute draft 

documents outside ED only with explicit authorization.

5. Generally, program offices answer the following:

a. logistical questions regarding the application submission process;

b. clarification questions pertaining to information in the NIA; or

c. questions to correct misconceptions (see Guidance below)

6. Program offices do not communicate with any person, entity, affiliate or third 

party in order to provide substantive guidance or tips on an individual 

application before submission.

7. Program offices post information about ED-sponsored meetings, webinars, 

and calls on ED’s website.

8. Program offices, for public inquiries regarding future grant competitions or for 

competitions currently underway, ensure that their responses are consistent

throughout the program and limited to the information ED has released 

publicly.
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9. Program offices track public inquiries to ensure consistency in responses, and 

inform information needs for future competitions.

B. Procedures – Reserved

C. Guidance

1. Program offices may engage in listening sessions and information gathering 

sessions with interested parties to share information regarding their goals or 

visions for grant programs, and future competitions and solicit opinions and 

feedback.

a. Listening sessions should include a broad range of parties and viewpoints.

b. The information obtained during these sessions should be considered 

equally with all available information.

c. Program offices should ensure that any information obtained during these 

listening sessions is done so in compliance with information collection 

requirements.

d. Decisions should be based on a complete representation of all views and 

opinions.

2. Program offices may conduct pre-application meetings and should include 

information about the pre-application meeting in the NIA when possible. Preapplication meetings are held after the NIA is published. Information about the 

pre-application meeting is posted on ED’s website, the program’s website, 

and other media sources to reach a wide pool of potential applicants.

a. Program offices must share with the program attorney all materials and 

information developed for the pre-application meeting.

b. A pre-application meeting may assist potential applicants with:

1) Eligibility requirements, including a discussion on how an applicant can 

establish that it is an eligible entity by setting out the relevant 

provisions of the NIA, applicable regulations, or the statute, but not by 

advising an applicant on whether it is eligible, or whether its proposal is 

allowable;

2) Developing application narratives and budgets;

3) Addressing the program’s selection criteria and priorities;

4) The standard that the applicant must meet for an absolute or 

competitive preference priority, if applicable;
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5) The applicability of the open-licensing requirement;

6) Specific requirements that apply to a competition, such as supplement 

not supplant, cost sharing or matching;

7) Allowable costs;

8) Reporting requirements;

9) Using Grants.gov for electronic submission of applications and 

procedures and deadlines for submission of applications;

10)Using other ED electronic business process software; and 

11)Administering their grants and mastering the fiscal management 

requirements in 2 C.F.R. §§ 200.302 - 303 and EDGAR. 

3. Materials used at the pre-application meeting must be 508 compliant and 

posted on the applicable program office’s website for the benefit of potential 

applicants who could not attend the meeting.

4. The following are examples of applicants’ logistical and programmatic 

misconceptions and permissible contact with the applicants by program office:

a. An applicant indicated that it would hand deliver its application to ED while 

visiting Washington, D.C. Program offices would correct the applicant’s 

misconception that paper copies were accepted and provide the logistical 

information for on-line application submissions or the waiver for paper 

copy submissions, and then refer the applicant to the Common 

Instructions or the program’s NIA, if applicable.

b. A Vocational Rehabilitation (VR) program provides services to American 

Indians with disabilities. One of the program’s goals is to provide these 

services in a “culturally appropriate manner.” Program staff realizes that 

an applicant, based on their questions, has a misconception regarding the 

meaning of the phrase “culturally appropriate manner.” Program offices, 

based on the grant program’s regulations and purpose, corrects the 

misconception of the phrase “culturally appropriate manner” by clarifying 

that it does not mean to take anything cultural and deliver it as a VR 

service; rather, it means to deliver the VR service in a manner that is 

culturally appropriate to the VR consumer.

c. Program offices track inquiries resulting from a NIA to help ensure 

consistency in responses. If tracking indicates a large number or similar 

misconceptions regarding the information in the NIA, program offices 

consult with their program attorney for assistance with developing FAQs, 
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application assistance information, or other guidance needed to post on 

the program’s website to widely share with all potential applicants.

5. Program offices may not follow up with applicants about their application 

during the peer review process (except in extremely limited technical 

exceptions, and after discussion with the program attorney).

6. Program offices may use various media and resources for outreach 

opportunities, other than pre-application meetings, for applicants to obtain 

information and receive technical assistance (TA). Some ideas for outreach 

include:

a. Program offices may use listservs and email communications to provide 

information and guidance about the NIA and application process if the 

listserv and email lists can target all potential applicants.

b. Program offices may use web-based technology as another way to reach 

potential applicants and provide them with TA or logistical assistance.

7. Program offices should invite the program attorney to participate in all preapplication meetings, webinars, and other outreach activities.

D. Other Pertinent Information – Reserved

2.5.8 General Education Provisions Act (GEPA) – Section 427

A. Policy

1. Section 427 of GEPA requires each applicant requesting funds (other than an 

individual person) to include in its application a description of the steps the 

applicant proposes to take to ensure equitable access to, and participation in, 

its Federally-assisted program for students, teachers, and other program 

beneficiaries with special needs.

2. The applicant, based on local circumstances, determines whether there are 

barriers that prevent participation in its Federally-assisted program by any 

person based on gender, race, national origin, color, disability, or age.

3. Program offices do not award a grant to an applicant that has not addressed 

the requirements of section 427 of GEPA in its application.

B. Procedures

1. Program offices include in all application packages OMB Form 1894-0005 

“Notice to All Applicants,” which addresses GEPA requirements, so that an 

applicant is aware that it needs to provide the information required under 

section 427 of GEPA.
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2. The application package informs applicants to identify the information 

submitted in response to the requirements of section 427 of GEPA. GEPA 

allows applicants to provide the information in a single narrative, or, if 

appropriate, it may be discussed in connection with related topics in the 

application.

3. Program offices screen all highly rated applications being considered for 

funding to ensure that applicants have addressed the requirements of section 

427 of GEPA, but applications are not rejected if the GEPA information is 

missing. If the information is not included in an application, program offices 

contact the applicant after selection to obtain the responses to the GEPA 427 

requirements.

C. Guidance – Reserved

D. Other Pertinent Information

1. OMB Form 1894-0005 “Notice to All Applicants” explains the requirements of 

section 427. That statute highlights six bases on which barriers may exist 

(i.e., denying equitable access or participation based on: gender, race, 

national origin, color, disability, or age).

2. Section 427 is not intended to duplicate the requirements of civil rights 

statutes, but rather to ensure that, in designing their projects, applicants for 

Federal funds address equity concerns that may affect the ability of certain 

potential beneficiaries to fully participate in the project and to achieve to high 

standards.

3. OMB Form 1894-0005 “Notice To All Applicants” is found within the 

Application Toolkit at the following link: Grant Application Toolkit. 

2.5.9 Grants.gov

A. Policy

1. The Government Paperwork Elimination Act, P.L. 105-277, Title XVII requires 

that all Federal agencies provide their customers the capability to conduct 

business electronically.

2. In accordance with the regulations at 2 C.F.R. § 200.204, ED requires grant 

applicants to use Grants.gov to apply for a discretionary grant, unless a grant 

program cannot use Grants.gov (e.g., fellowships).

3. Program offices use the standard form (SF) “Application for Federal 

Assistance” (SF-424 and Supporting Documents) and the “ED Supplement to 

the SF-424” form in their application packages in order to have their grant 

program competitions participate in the Grants.gov Apply site.
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4. To apply through Grants.gov and to do business with ED, applicants must 

have a UEI Number, have a TIN, and be registered in SAM.

5. An entity wishing to apply to ED for grant funding must establish a UEI 

number for each of its physical locations. Some grantees that apply for grant 

funding have established a separate UEI number for their organizational 

components (e.g., an entity’s business or finance office) that will be 

responsible for drawing down grant funds from ED.

B. Procedures

1. Applications and all attachments transmitted to Grants.gov for ED programs 

will be posted using Adobe forms and PDF formats. The entire application, 

including attachments, comply with the requirements concerning the content 

and format of an application as described in the grant program’s application 

package and NIA.

2. When an applicant has successfully transmitted its application in Grants.gov, 

it receives an automatic acknowledgement from Grants.gov that contains a 

Grants.gov tracking number. The applicant also receives an automatic email 

reflecting that the application met all the Grants.gov validation requirements 

or reflecting that there were errors in the submission. Grants.gov acceptance 

of an application does not mean the applicant complied with all ED’s 

application requirements (e.g., if the applicant submitted an Excel table 

instead of a PDF or Word document). Applicants must submit applications in 

accordance with all the requirements addressed in the NIA and application 

package.

3. For applications that meet all the Grants.gov validation requirements, the

grants management system interfaces with Grants.gov by automatically 

transmitting the application information from Grants.gov to the grants 

management system. Program offices are then able to view the application in 

the grants management system within the applicable functionality. 

C. Guidance

1. Program offices should review ED’s Common Instructions for information 

regarding the submission of applications via Grants.gov. 

D. Other Pertinent Information

1. The UEI number is a unique nine-digit identifier for entities that is used to 

establish an entity credit file, which is often referenced by the Federal 

government to help predict the reliability and/or financial stability of the entity 

in question. Additionally, OMB has adopted the use of the UEI number to 

identify entities that receive grant awards and to track how grant funding is 

dispersed.
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2. The following are all considered TINs according to the IRS:

a. Social Security Number “SSN” 

b. Employer Identification Number “EIN” 

c. Individual Taxpayer Identification Number “ITIN” 

d. Taxpayer Identification Number for Pending U.S. Adoptions “ATIN” 

e. Preparer Taxpayer Identification Number “PTIN” 

3. The Grants.gov Apply site includes instructions (Education Submission 

Procedures) on how an applicant can complete its application online in 

Workspace, a collaborative web-based tool, and submit the application to the 

Federal agency handling the program from which funds are being sought 

through the Apply site. Grants.gov provides an index for NIAs by ALN for the 

relevant competition.

2.5.10 Electronic Application Processing for Fellowships or 

Exceptions

A. Policy

1. ED designates its own grants management system as the alternative 

application submission system for those grant programs that cannot utilize 

Grants.gov for application submission.

B. Procedures

1. Program offices, at the beginning of the fiscal year, identify all potential grant 

competitions that may require application submissions in the grants 

management system, and respond to the Business Systems Support 

Division’s (BSSD) annual call for the identification of these programs.

2. Program offices consult with BSSD staff about using the grants management 

system and not Grants.gov. 

3. For program offices requiring application submission in the grants 

management system, program offices announce in their NIA that applications 

are submitted via the grants management system. 

4. Program offices with competitions that require applicants to submit their 

applications using the grants management system explain in the NIA the 

waiver procedures for applicants who are unable to submit their applications 

electronically.
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5. Applicants that submit their applications through the grants management 

system complete the standard form, “Application for Federal Assistance” (SF424 and Supporting Documents), and the “ED Supplement to the SF-424” 

form.

6. The UEI and TIN registration requirements set forth for Grants.gov application 

submission are also applicable when applicants apply using the grants 

management system. 

7. When applications are submitted electronically using the grants management 

system, the system: 

a. Assigns the application a PR/Award number (i.e., a unique ED-specified 

identifying number that is assigned to each ED application);

b. Provides the applicant with an immediate confirmation of the receipt of the 

application;

c. Sends out an email confirmation of application receipt to all registered 

users who worked on the electronic application;

d. Stores all data received from the electronic applications in the system 

database, and uses the data to populate any data fields that are manually 

entered for paper applications; and

e. Makes the applications received available for electronic review through eReader software (see the section e-Reader - Peer Review System).

C. Guidance – Reserved

D. Other Pertinent Information

1. The grants management system provides applicants the capability to 

complete application forms online, attach narrative documents relating to the 

applications, and submit the entire document to ED.

2.6 Novice Applicants and New Potential Grantees 

2.6.1 Novice and New Potential Grantees Application Procedures

A. Policy

1. Program offices have the option of giving special consideration to novice 

applicants or applications from new potential grantees to broaden and 

diversify the pool of applicants that apply for ED discretionary grant awards, 

and to provide greater opportunities for inexperienced applicants to receive 
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funding. Given the flexibilities afforded by the new potential grantee priority, 

programs should use that priority instead of the novice priority.

2. The Administrative Priorities, available at Federal Register Notice 85 FR 

13640, include a priority for Applications from New Potential Grantees. The 

priority includes a number of subparts from which a program office can 

choose when using this priority in a grant competition. Program offices can 

choose to use this priority as an absolute, competitive preference, or 

invitational priority when:

a. The applicant has never received a grant, including through membership 

in a group application submitted in accordance with EDGAR §§ C.F.R. 

75.127-75.129, under the program from which it seeks funds.

b. The applicant does not, as of the deadline date for submission of 

applications, have an active grant, including through membership in a 

group application submitted in accordance with EDGAR §§ C.F.R. 75.127-

75.129, under the program from which it seeks funds.

c. The applicant has not had an active discretionary grant under the program 

from which it seeks funds, including through membership in a group 

application submitted in accordance with EDGAR §§ C.F.R. 75.127-

75.129, in one of the following number of years before the deadline date 

for submission of applications under the program:

1) One year;

2) Two years;

3) Three years;

4) Four years;

5) Five years;

6) Six years; or

7) Seven years.

d. The applicant has not had an active discretionary grant from ED, including 

through membership in a group application submitted in accordance with 

EDGAR §§ C.F.R. 75.127-75.129, in one of the following number of years 

before the deadline date for submission of applications under the program:

1) One year;

2) Two years;
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3) Three years;

4) Four years;

5) Five years;

6) Six years; or

7) Seven years.

e. The applicant has not had an active contract from ED in one of the 

following number of years before the deadline date for submission of 

applications under the program:

1) One year;

2) Two years;

3) Three years;

4) Four years;

5) Five years; 

6) Six years; or

7) Seven years.

f. For the purpose of the priority, a grant or contract is active until the end of 

the grant’s or contract’s project or funding period, including any extensions 

of those periods that extend the grantee’s or contractor’s authority to 

obligate funds.

3. The definition of “novice applicant” and procedures for prioritizing novice 

applicants are found in in EDGAR § 75.225. Generally, a novice applicant for 

a grant is an entity that has:

a. Never received a grant or subgrant under the program from which it seeks 

funding;

b. Never been a member of a group application, submitted in accordance 

with EDGAR §§75.127-75.129, that received a grant under the program 

from which it seeks funding; and

c. Not had an active grant from the Federal government in the five years 

before the deadline date for applications under the grant program from 

which it seeks funding.
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B. Procedures

1. Program offices ensure that the novice applicant or new potential grantees 

procedures are only used for those programs where they are legally 

permissible and consistent with the intent and purpose of the program.

2. Program offices provide information about the novice application or new 

potential grantee procedures used for a competition in the ATRP (see the 

section Contents of the ATRP).

3. Program offices using novice application or new potential grantees 

procedures include instructions in the application package directing applicants 

to respond to item 2 on the “ED Supplement to the SF-424” form, which asks 

whether the applicant is a novice applicant as defined in EDGAR § 75.225 or 

a new potential grantee (as described in the priority included in the NIA). If a 

program is not using novice application or new potential grantees procedures, 

applicants are instructed to leave item 2 blank.

4. In accordance with EDGAR § 75.225, when giving special consideration to 

novice applicants, program offices may either:

a. Establish a separate competition for novice applicants; or

b. Include novice applicants in the general program competition, but give 

competitive preference (i.e., additional bonus points) to novice applicants.

5. In accordance with the Administrative Priorities, when giving special 

consideration to new potential grantees, program offices may:

a. Establish a separate absolute priority for new potential grantees; or

b. Include new potential grantees in the general program competition, but 

give competitive preference (i.e., additional bonus points) to new potential 

grantees.

C. Guidance – Reserved

D. Other Pertinent Information

1. Novice application or new potential grantees procedures are more 

appropriate for certain types of programs than others. For example, novice 

application or new potential grantees procedures might be more appropriate 

for use in training, service, or demonstration programs, rather than in highlycomplex research projects.
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2.6.2 Separate Competitions for Novice and New Potential Grantees

A. Policy

1. Program offices, when establishing a separate competition for novice 

applicants:

a. Determine the estimated number of awards and the estimated level of 

funding that will be made available for the new potential grantees 

competition, and the general program competition. This information is 

included in the POC’s annual spending plans.

b. Publish an NIA in the Federal Register for the novice or new potential 

grantees competition, or one NIA containing absolute priorities for both the 

general program competition and the novice or new potential grantees 

competition. When publishing separate NIAs, information about the novice 

or new potential grantees competition may be included for information 

purposes in the NIA that is used for the general program competition (see 

the section Notice Inviting Application).

c. Include in the NIA, or application package, the application limitations for 

novice or new potential grantees applications in a competition (e.g., 

deadline submission date), as appropriate.

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information - Reserved

2.6.3 Competitive Preference for Novice and New Potential Grantees

A. Policy

1. ED regulations establish that program offices have the option of including 

novice applicants or new potential grantees in the general program 

competition, but also awarding them competitive preference (i.e., additional 

bonus points) in order to broaden and diversify the pool of applicants that 

apply for ED discretionary grant awards, and to provide greater opportunities 

for inexperienced applicants to receive funding.

B. Procedures

1. Program offices must follow the procedures in EDGAR § 75.105©(2) when 

giving competitive preference (i.e., additional bonus points) to novice 

applicants and new potential grantees under the general program 

competition.
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2. Program offices specify the number of competitive preference points that will 

be awarded to novice applicants or new potential grantees in the NIA for the 

competition. All applicants under the competition that meet the definition of 

novice applicant in EDGAR § 75.225 (a) or the subparts of the Applications 

from New Potential Grantees Administrative Priority are awarded the same 

number of bonus points.

3. The program office’s determinations about the number of bonus points 

awarded to novice applicants or new potential grantees are weighed carefully 

against quality concerns (see Other Pertinent Information below).

4. If a novice applicant or new potential grantee comes into the funding range 

solely based on the bonus points it received as a novice applicant or new 

potential grantee, program offices review the application, similar to an 

applicant previously awarded funds, to determine if the applicant has the 

fiscal and programmatic ability and internal controls to implement the award.

5. Generally, weaknesses in applications from novice applicants or new 

potential grantees can be addressed by including specific conditions on the 

award (see the section Special Conditions for Novice Grantees).However, if 

program offices are concerned that specific conditions would not be sufficient 

to help the applicant succeed, they note those extensive weaknesses in the 

Grant Funding Slate (see the ED Grant Funding Slate Template for 

requirements and guidance about what to include when recommending that 

an application be skipped). The Secretary may skip the applicant on the Grant 

Funding Slate if the analysis of the weaknesses supports that decision.

C. Guidance – Reserved

D. Other Pertinent Information

1. See the section Peer Review Scoring and Quality Control for information 

about detecting problems in reviewer scoring practices, which may be helpful 

when encountering scoring anomalies related to novice applicants or new 

potential grantees.

2.6.4 Novice and New Potential Grantees Designation and 

Certification

A. Policy

1. Applicants wishing to be considered as novice applicants or new potential 

grantees self-identify as such, and program offices verify the accuracy of 

applicants’ novice applicant or new potential grantee status.
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B. Procedures

1. For programs giving competitive preference to novice applicants or new 

potential grantees, applicants are instructed to check either the “Yes” or “No” 

box included in item 2 of the “ED Supplement to the SF-424” form to indicate 

whether they qualify as novice applicants or new potential grantees.

2. To separate novice or new potential grantees competitions, applicants are 

told that only those who can check the “Yes” box on item 2 of the “ED 

Supplement to the SF-424” form are eligible for those competitions. By 

checking “Yes,” an applicant certifies that it meets the novice applicant 

requirements in EDGAR § 75.225 or for Applications from New Potential 

Grantees in the NIA.

3. When the competition is giving competitive preference to novice applicants, 

program offices review USASpending.gov to determine if an applicant is a 

novice applicant (i.e., the applicant has not received a grant within the past 

five fiscal years), or if there is evidence suggesting that the applicant may not 

be a novice applicant (e.g., a major research university is applying as a 

novice applicant).

4. When a group application is submitted in accordance with EDGAR §§ 75.127- 

75.129, all members of the group must meet the novice applicant definition 

(see EDGAR § 75.225 (a) (1) and (a)(2)). By checking the “Yes” box on item 

2 of the “ED Supplement to the SF-424” form, the entity that is designated by 

the group to apply for the grant is certifying that each member of the group 

meets the novice applicant requirements. Further, in accordance with EDGAR 

§ 75.128, the members of the group must enter into an agreement that, 

among other requirements, binds each member of the group to every 

statement and assurance made by the applicant in the application. The 

applicant must submit this agreement with its application.

5. When the competition is giving competitive preference to new potential 

grantees, program offices review the award history for that applicant in the

grants management system to determine if an applicant is a new potential 

grantee, as established in the NIA, or if there is evidence suggesting that the 

applicant may not be a new potential grantee (e.g., the applicant does not 

comply with the requirements for a new potential grantee as established in 

the NIA).

C. Guidance – Reserved

D. Other Pertinent Information - Reserved
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2.6.5 Pre-Application Technical Assistance for Novice Applicants and 

New Potential Grantees

A. Policy - Reserved

B. Procedures – Reserved

C. Guidance

1. For program offices giving special consideration to novice applicants or new 

potential grantees, program offices may conduct technical assistance 

workshops to assist applicants in preparing their applications (see the section 

Communication with the Public about Competitions). These workshops 

should provide inexperienced novice applicants or new potential grantees 

with the information needed to submit high-quality grant applications.

D. Other Pertinent Information - Reserved

2.6.6 Special Conditions for Novice Applicants

A. Policy

1. The regulations in EDGAR § 75.225 (d) provide program offices the authority, 

independent from 2 C.F.R. § 200.208, to impose special conditions, if 

necessary, before making grants to novice applicants The Administrative 

Priorities do not include this same authority.

B. Procedures – Reserved

C. Guidance

1. Before awarding a grant to a novice applicant, program offices may impose 

special conditions, if necessary, in accordance with EDGAR § 75.225 (d), to 

ensure that the grant is managed effectively and project goals or objectives 

are achieved. For example, a novice grantee might be required to submit 

quarterly performance reports to help facilitate close monitoring of the project, 

see the section Grant Performance – Addressing Risk and Other Issues. The 

Administrative Priorities do not include this same authority.

D. Other Pertinent Information – Reserved
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2.7 Faith-Based Organizations

A. Policy

1. Program offices comply with the requirements in EDGAR § 75.52, including 

the ones listed below, when administering grant programs to which faithbased organizations may apply for and receive a grant:

a. A faith-based organization is eligible to apply for and receive an ED grant 

under a program on the same basis as any other private organization, with 

respect to programs for which such other organizations are eligible. ED 

shall provide such religious accommodation as is consistent with Federal 

law, the Attorney General’s Memorandum of October 6, 2017 (Federal 

Law Protections for Religious Liberty), and the Religion Clauses of the 

First Amendment to the U.S. Constitution.

b. In the selection of grantees, ED does not discriminate for or against a 

private organization based on the organization’s religious character, 

affiliation, or exercise and ensures that all decisions about grant awards 

are free from political interference, or even the appearance of such 

interference, and are made based on merit, not based on religion or 

religious belief, or the lack thereof. Notices or announcements of award 

opportunities and notices of award or contracts shall include language 

substantially similar to that in Appendices A and B to Part 75. 

c. No grant document, agreement, covenant, memorandum of 

understanding, policy, or regulation that is used by ED shall require faithbased organizations to provide assurances or notices where they are not 

required of non-faith-based organizations. Any restrictions on the use of 

grant funds shall apply equally to faith-based and non-faith-based 

organizations. All organizations that receive grants under an ED program, 

including organizations with religious character or affiliation, must carry out 

eligible activities in accordance with all program requirements, subject to 

any required or appropriate religious accommodation, and other applicable 

requirements governing the conduct of Department-funded activities, 

including those prohibiting the use of direct financial assistance to engage 

in explicitly religious activities.

d. No grant document, agreement, covenant, memorandum of 

understanding, policy, or regulation that is used by ED shall disqualify 

faith-based organizations from applying for or receiving grants under an 

ED program because such organizations are motivated or influenced by 

religious faith to provide social services, or because of their religious 

character or affiliation, or on grounds that discriminate against 

organizations on the basis of the organizations’ religious exercise.
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e. The provisions of EDGAR § 75.532, “Use of funds for religion prohibited,” 

apply to any organization, including a faith-based organization, that 

receives a grant under an ED program.

f. A private organization that receives a grant under an ED program and 

engages in explicitly religious activities, such as worship, religious 

instruction, or proselytization, must offer those activities separately in time 

or location from any programs or services supported by a grant from ED, 

and attendance or participation in any such explicitly religious activities by 

beneficiaries of the programs and services funded by the grant must be 

voluntary.

2. If a grantee has the authority under a grant to select a private organization to 

provide services by subgrant, contract, or other agreement, the grantee must 

ensure compliance with applicable Federal requirements governing contracts, 

grants, and other agreements with faith-based organizations, including, as 

applicable, EDGAR §§ 75.52 and 75.532, Appendices A and B to Part 75, 

and 2 C.F.R. § 3474.15 (see EDGAR § 75.714). 

B. Procedures

1. Program offices include language in their NIAs and grant awards that clarifies 

the rights and obligations of faith-based organizations that apply for and 

receive Federal funding (see Appendices A and B to Part 75).

2. Program offices ensure that a grantee that has the authority under its grant to 

select a private organization to provide services by a subgrant contract or 

other agreement is aware if it responsibilities under EDGAR § 75.714. 

3. Programs offices consult with the program attorney when specific conditions 

are to be imposed on faith-based organizations in accordance with item 1 

under the Guidance section below.

C. Guidance

1. Many faith-based organizations are relatively new to Federal grants 

management, so program offices may deem it appropriate, as with other 

novice applicants and new potential grantees, to provide technical assistance 

and impose specific conditions to help safeguard Federal funds against 

misuse and ensure successful project outcomes.

2. During the planning phase, program offices may consider the following 

options for addressing faith-based organizations:

a. Incorporating language in NIAs and in grant application packages that 

specifically identify faith-based organizations as eligible applicants under a 

program competition.
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b. Providing FAQs that identify allowable and unallowable expenditures and 

activities pertaining to faith-based organizations.

c. Conducting pre-application workshops that include guidance addressing 

the rights and responsibilities of faith-based organizations and their 

beneficiaries.

D. Other Pertinent Information - 

1. Appendices A and B to Part 75 clarify the rights and obligations of faith-based 

organizations that apply for and receive Federal funding. The Appendices A 

and B to Part 75 are included at Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process

2.8 Proving Non-profit Status

A. Policy

1. Program offices require that non-profit applicants demonstrate their non-profit 

status in their applications consistent with the requirements in EDGAR. 

2. This policy is only applicable to programs that include non-profits as eligible 

applicants.

B. Procedures

1. Program offices publish in the NIA that applicants may demonstrate their nonprofit status by any of the following means (See EDGAR § 75.51):

a. Proof that the IRS currently recognizes the applicant as an organization to 

which contributions are tax deductible under section 501©(3) of the 

Internal Revenue Code;

b. A statement from a State taxing body or the State attorney general 

certifying that:

1) The organization is a non-profit organization operating within the State; 

and

2) No part of its net earnings may lawfully benefit any private shareholder 

or individual;

c. A certified copy of the applicant’s certificate of incorporation or similar 

document if it clearly establishes the non-profit status of the applicant; or
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d. Any item described in this section when that item applies to a State or 

national parent organization, together with a statement by the State or 

parent organization that the applicant is a local non-profit affiliate.

C. Guidance

1. Program offices may contact the Regulations Quality Officer or the 

Regulations Coordinator in RSD for guidance about addressing this 

requirement in the NIA.

D. Other Pertinent Information 

1. Program offices may use the IRS Tax Exempt Organization Search lookup 

function to help confirm whether an applicant holds a non-profit status 

available at: https://apps.irs.gov/app/eos/. 

2.9 Funding Definitions and Periods of Funding

This section provides pertinent background information that explains appropriations, 

frontloading flexibilities, and ED’s established system of budget periods and project 

periods (established in accordance with EDGAR §§ 75.250 and 75.251) through which 

ED divides funding of single and multi-year grants.

2.9.1 Appropriations

A. Policy

1. Appropriated funds are generally identified as one-year, multiple-year, or noyear. This references the “period of availability,” or the period during which 

the Federal government obligates (i.e., award) funds, after which the funds 

are expired. Subject to the terms and conditions of the GAN, grantees may 

continue to make drawdowns after Federal availability has expired. 

Availability to grantees ends upon cancellation, and the unexpended funds 

revert to the U.S. Department of the Treasury (Treasury) upon cancellation.

2. One-year funds and multiple-year funds are, with rare exception, cancelled 5 

years after the Federal period of availability ends; unexpended funds revert to 

Treasury upon cancellation.

3. No-year funds neither expire nor cancel, making their availability time to both 

ED and grantees indefinite.

4. There are instances in which program offices can obligate funds for grants in 

a given FY even if the project period does not start until the subsequent fiscal 

year. Program offices consult with Budget Service before doing so.
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B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information

1. The Constitution vests Congress with the responsibility for authorizing the 

expenditures of the Federal government. An appropriations act is a law 

passed by both houses of Congress and signed by the President that 

provides budget authority for a specific purpose. In appropriations acts, 

Congress identifies the purposes, periods of time, and amounts for all Federal 

expenditures. The Executive Branch, which includes the President and 

Federal agencies, cannot transfer funds from one appropriated category to 

another without explicit authority or approval from Congress nor can they 

expend funds that have not been appropriated. The Anti Deficiency Act 

prohibits obligating or expending funds in advance of or in excess of the 

appropriation.

2. The Office of Financial Management (OFM) in the Office of Finance and 

Operations (OFO) provides monthly appropriations monitoring reports 

(starting the first of November), which identifies funds that will revert to 

Treasury by October 1st. For copies of these reports, program offices contact 

OFM.

2.9.2 Frontloading versus Forward Funding

A. Policy

1. Frontloading - is an informal term that commonly describes the use of 

appropriated funds available for obligation in a particular fiscal year to fund, in 

whole or in part, future budget periods of the award. As a matter of policy, 

program offices avoid frontloading whenever possible, as it is ED’s goal to 

maximize the number of new awards to promote innovation in education. 

When circumstances exist in which frontloading may be appropriate, or even 

unavoidable, see item 2 in the Guidance section. Program offices, in 

consultation with Budget Service, identify such circumstances as soon as 

possible in the grantmaking process and secure approval from OPEPD/GPO 

and OS prior to implementing a frontloading plan.

2. Forward Funding – is not the same as “frontloading.” “Forward funding” 

applies to the period of availability of funds appropriated for certain Federal 

programs. Specifically, in certain Federal grant programs (primarily formula 

grant programs), the period of availability for some or all of a program’s funds 

may be delayed until after the start of the fiscal year, or even until a future 

fiscal year. In particular, the term “forward funding” applies to funds that 
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become available beginning late (typically in the last quarter) in the budget 

year and are carried forward into at least one following fiscal year.

a. A common example of forward funding is when Congress may appropriate 

funds in a given fiscal year that become available in July of the following 

calendar year and remain available for obligation through the end of the 

subsequent fiscal year (see 20 USC § 1223).

B. Procedures

1. In general, a proposal to frontload grants is:

a. Documented in the program office’s spending plan and approved by 

Budget Service in consultation with OPEPD/GPO and OS.

b. Agreed upon during a planning or pre-clearance meeting (with 

representatives from the relevant POC, OPEPD/GPO, OGC and the 

Budget Service) before NIAs go into clearance; and

c. Documented in the program’s Grant Funding Slate and approved by 

OPEPD/GPO.

2. Merely describing a frontloading proposal in a spending plan, pre-clearance 

meeting, and/or Grant Funding Slate does not guarantee approval of that 

proposal. Program offices consult with their Budget Service analyst as soon 

as possible when considering frontloading; the Budget Service analyst helps 

program offices determine whether the circumstances are appropriate for 

frontloading and guides program offices through the review of its proposal.

3. Program offices consult with their program attorney to ensure that a 

frontloading plan meets all applicable legal and administrative requirements.

4. Each frontloading plan submitted to Budget Service includes a description of 

how frontloaded funds will be distributed among eligible grantees. For 

example, program offices should consider the following factors:

a. Fiscal and performance history; 

b. Available information about risk;

c. Point in the grant cycle (i.e., whether a grantee is entering Year 4 of the 

grant cycle or Year 2); and

d. Size of annual award.

5. Program offices add the following condition in Box 10 of the GAN when 

frontloading a grant:
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“This grant is a frontloaded grant, i.e., funds indicated in Block 7 were requested 

by the grantee, and approved by the Department, for expenditure in more than one 

budget period. For the current budget period and any subsequent budget period, the 

grantee may only draw down funds in accordance with its approved budget and may 

not draw down funds in excess of that amount without prior approval.”

C. Guidance

1. When fully frontloading a five-year grant, program offices should be aware 

that funds will cancel and revert to Treasury five years after the period of 

availability ends. As such, grantees have limited ability to take advantage of 

the liquidation period or no-cost extension of the project period. Program 

offices should proactively notify grantees of such limitations and ensure timely 

drawdown of funds in advance of cancellation.

2. Below are a few illustrative examples of scenarios that might warrant approval 

of frontloading. Relying on one of the rationales below does not guarantee 

approval; rather, decisions will be made on a case-by-case basis considering 

the specific circumstances of each request.

a. The program has funding available after preparing funding 

recommendations, but not enough to fully fund an additional award.

b. Using all funds available for new awards could lead to funding shortfalls in 

out- years. 

c. A grant slate includes an insufficient number of high-quality, high-scoring 

applications to use all funds available for new awards.

d. The amount of funds available after paying continuation costs for prioryear grantees is insufficient to support a new competition (and funding 

down a prior year’s slate is not an option).

e. There is a policy rationale for maximizing the funds available in a 

subsequent fiscal year (e.g., to support a more rapid transition to a 

reauthorized program authority, ensure robust funding for a key policy 

initiative, or take advantage of rulemaking).

D. Other Pertinent Information – Reserved

2.9.3 Project Periods

A. Policy

1. A project period, also referred to as the period of performance encompasses 

the entire period during which obligation may be incurred against the award. 

Under EDGAR § 75.250, ED can fund a project for up to 60 months unless a 
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program statute or regulation provides for a longer project period. A project 

period can also be less than 60 months and may even be less than a year.

2. In accordance with EDGAR § 75.250(b), ED approves a data collection period 

for a grant for a period of up to 72 months after the end of the project period 

and provides funding for the data collection period for the sole purpose of 

collecting, analyzing, and reporting performance measurement data regarding 

the project.

B. Procedures – Reserved

C. Guidance

1. Program offices may inform applicants of the intent to approve data collection 

periods in the grant competition NIA or may decide to fund data collection 

periods after grantees have started their project periods.

D. Other Pertinent Information

1. There are times when project periods may be extended at no cost to ED. For 

information about no cost extensions of a project period, see the section 

Extension of the Final Budget Period. 

2.9.4 Budget Periods

A. Policy

1. When ED funds grants with project periods longer than a year, it generally 

funds the grants in annual increments called budget periods. A budget period 

is usually 12 months (see EDGAR § 75.251), and funding for each budget 

period generally comes from separate fiscal year appropriations (see the 

section Appropriations).

B. Procedures – Reserved

C. Guidance

1. Program offices may establish shorter or longer budget periods if there is a 

compelling program reason to do so, such as:

a. To arrange more advantageous start and end dates for the grantee;

b. To allow for project periods not evenly divisible into 12-month increments;

c. To consider an unavoidable extended absence of a grantee’s principal 

investigator; or,
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d. To accommodate a change in the grantee’s fiscal year.

2. A single budget period covering the entire project period, in which the entire 

grant award is funded at the same time, will generally be used if:

a. The budget period is greater than a year, but less than two years;

b. This method of funding is required by authorizing statute, funding 

appropriation, or to satisfy the intent of Congress;

c. The project is exclusively for construction, alteration or renovation, 

acquisition of property, and is funded from a multi-year or “no-year” 

appropriation; or

d. The project period is two years or longer, and the program attorney 

concurs with the longer budget period.

3. Programs document the reason(s) for establishing shorter or longer budget 

period(s) in the official grant file.

D. Other Pertinent Information – Reserved
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Chapter 3: Review Activities

3.1 Introduction

The discretionary grant technical review process includes the activities necessary 

to carry out a fair and objective evaluation of applications submitted for funding. This 

chapter addresses ED’s responsibilities to conduct fair and objective technical 

reviews of applications submitted to a competition for funding, including by using 

highly qualified application reviewers. Specifically, this chapter focuses on:

1. Developing and approving the ATRP;

2. Developing, maintaining, and closing the Grant Program Competition File;

3. Receiving and screening applications;

4. Peer reviewers;

5. Inherently governmental functions;

6. Conflicts of interest; and

7. Peer review scoring and quality control;

3.2 Developing and Approving the ATRP

3.2.1 Developing the ATRP

A. Policy

1. Program offices develop Application Technical Review Plans (ATRPs) based 

on legal requirements and policy decisions made through the spending plan 

process, including any priorities established for competitions.

a. Principal Officers, or their delegee(s), approve every ATRP by the 

application closing date.

B. Procedures

1. Program offices establish one ATRP that covers all discretionary grant 

programs or multiple ATRPs that, together, cover all discretionary grant 

competitions.

2. If only one ATRP is developed for a program office, all discretionary grant 

competitions conducted by that program office use that ATRP and the same 
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selection procedures for the grant programs they administer, including any 

additional procedures required by each program’s statute and regulations.

a. If programs wish to use different selection procedures for different 

discretionary grant competitions, they develop multiple ATRPs.

3. Program offices give their program attorney the opportunity to review their 

ATRPs for each competition.

4. The approved ATRP is included in the Grant Program Competition File.

5. If a Principal Officer delegated approval authority to another individual, that 

individual provides a copy of the approved ATRP to the Principal Officer.

6. If there is a need to deviate from or change the ATRP during a competition, 

and the deviation or change is substantive, the program official proposing the 

deviation or change submits the revision to their program attorney for review.

a. Program officials, after OGC review, submit both the amendment and a 

written justification for the amendment to the Principal Officer or to the 

individual who was delegated the authority to approve the ATRP. The 

revised ATRP is dated and edited so that the modifications are clearly 

identifiable. The revised ATRP becomes the official ATRP of record. 

Approved amendments and written justifications are included in the 

Competition File.

7. If a Principal Officer delegated approval authority to another individual, that 

individual provides a copy of the approved amended plan and written 

justification to the Principal Officer.

8. If the Principal Officer determines there is a need to deviate from the rank 

order in a manner not already specified in the ATRP, program offices do not 

need to amend the ATRP to reflect these decisions. However, the Grant 

Funding Slate includes a statement that the funding recommendation 

deviates from the ATRP, and a justification for the deviation (see the Grant 

Funding Slate Template for requirements and guidance about what to include 

when there is a need to deviate from the ATRP). Additionally, the Grant 

Program Competition File includes documentation supporting the deviation.

C. Guidance

1. Program offices are encouraged to consult internally and with other POCs, as 

appropriate, when developing new ATRPs or amending existing ATRPs. For 

example, it may be appropriate to consult with another POC that already 

conducts a multi-tier review when considering this type of review for a new 

program.
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2. If the ATRP is the same from one year to the next, with only minor changes 

(e.g., dates of the review, and the number and size of the panels), program 

offices may use a copy of the original ATRP and update it as needed.

D. Other Pertinent Information

1. Program offices may use the ATRP Content Checklist as a resource when 

developing the ATRP, which is available at the following link: Documents and 

Forms Referenced in the Handbook for the Discretionary Grant Process. 

3.2.2 Contents of the ATRP

A. Policy

As applicable, the following items are included in the ATRP.

1. Identification of the logistical contractor to be used for support during the 

ATRP, including defined roles and responsibilities of the contractor, and the 

expected timelines for deliverables (see the sections One Percent Set-Aside 

for Peer Review and Inherently Governmental Functions and Contractors).

2. Review panel information, including:

a. The schedule for review of applications;

b. The size of the panels and, if known, the number of panels and reviewers;

c. A description of how applications will be assigned to panels; and

d. A description of whether peer review panels will be conducted on-site or 

remotely.

3. A description of the process pertaining to the involvement and treatment of 

the application reviewers including:

a. The standards and evaluation criteria to be used in recruiting and 

selecting reviewers (Federal, if allowed by the program statute and 

regulations, and non- Federal);

b. The process for identifying reviewers with a conflict of interest (see the 

section Conflict of Interest);

c. A commitment to provide reasonable accommodations for reviewers with 

disabilities;
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d. A description of the orientation that will be provided to the reviewers, 

including orientation materials, to the extent they are available (see the 

section Packages for Peer Reviewers);

e. A description of the procedures that will be used to ensure that each 

reviewer on a panel will independently review the applications assigned to 

the panel before any group panel discussion occurs;

f. A description of the procedures that will be used to replace or remove a 

reviewer in situations where the reviewer is either unable or unwilling to 

perform his or her job (see the section Replacement of Reviewers During

the Review); and

g. A copy of the Technical Review Forms (TRFs) that reviewers will use to 

assess the quality of the applications.

4. A description of the process for identifying and resolving conflicts of interest 

including:

a. The procedure for reviewers to follow when checking the entire list of 

applications received under the competition prior to the beginning of the 

review so that conflicts of interest can be identified;

b. A description of how conflicts of interest will be minimized, and when they 

occur, how they will be resolved;

c. If program offices anticipate that a large group exemption for conflicts of 

interest, described in the Conflict of Interest Exemption for Large 

Competitions section, is applicable, the ATRP states this conclusion and 

documents that each condition required for utilizing the exemption has 

been met. To the extent possible, the plan also identifies any additional 

conflict waivers that might be requested in accordance with the Individual 

Conflict of Interest Waivers section; and

d. The steps to be taken to address factors that might affect objectivity, such 

as a teaching methodology, pedagogical viewpoint, or philosophical 

viewpoint, involved in the competition that a peer reviewer may be 

associated with or connected to (see the Guidance section that follows

below, and the section Process for Addressing Other Factors That Might 

Affect Objectivity).

5. A description of how program offices will work with the panels, including:

a. A description of the criteria program offices will use to determine when to 

meet with a panel to solicit discussion of a particular application or group 

of applications (see the section Roles and Responsibilities in the Review 

Process).
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6. A description of the procedures that will be used to ensure a high-quality peer 

review, including a description of the manner by which program offices will 

resolve widely-varying scores based on a different understanding among the 

application reviewers of the application content or selection criteria and/or 

priorities (see the section Peer Review Scoring and Quality Control).

7. A description of how applications:

a. Will be selected for funding (e.g., rank order listing, published priorities, 

other information that will be used under EDGAR § 75.217);

b. Will be managed if two or more receive the same score; and

c. Will be modified, without changing the scope or objectives of the original 

application, when they are within funding range, but available program 

funds cannot support the applicants’ requested amount.

8. A description of the process for addressing evidence or evaluation 

requirements pertinent to the competition, including:

a. A description of the procedures that will be used to ensure applicants have 

met the evidence or evaluation requirements, including the role of both 

Federal and non-Federal reviewers; and

b. A description of how these requirements will affect the rank order or 

selection of applications for funding.

9. A statement of the kind of funding priority (absolute, competitive preference, 

invitational) that will be given to Novice and New Potential Grantees 

Applications (see the section Novice Applicants and Applications From New 

Potential Grantees and EDGAR § 75.225).

10.A description of how applications will be selected when a multi-tier review 

process is used; see the section Multiple-Tier Application Review. 

11.A description of the circumstances under which the Principal Officer will use 

an order of selection different than the rank order of applicants and the 

documentation requirements for such an order of selection. While, under item 

g(i) of this section, a description of “how” applications will be selected will be 

provided, the circumstances describing “why” an alternative selection method 

is to be used will be described under this item. For example, a program office 

states it awards grants based on regional distribution under g(i), describes, 

under this item, that this selection process is required in accordance with the 

applicable statute or regulation, if in fact the program’s statute or regulation 

requires this selection.
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12.The transparency plan that will be implemented for the discretionary grant 

competition (see the section Transparency).

B. Procedures

1. When including the steps that will be taken to address factors that might 

affect objectivity, such as a teaching methodology, research methodology, 

pedagogical viewpoint, or philosophical viewpoint involved in the competition 

that a peer reviewer may be associated with or connected to, programs 

should include, in the ATRP, language similar to the following:

“When reviewers disclose that they have written, published, or otherwise 

commented on or been connected to any specific teaching methodology, research 

methodology or significantly identified with any pedagogical or philosophical 

viewpoints associated with a competition, and further explain that their connection or 

significant identification may cause someone to question their objectivity, program 

offices will: 1) review the responses to question 7 in “Questions for Application 

Reviewers on Conflict of Interest and Other Factors That Might Affect Objectivity”; 2) 

request and review applicable copies of written and/or published works as deemed 

appropriate by program office; and 3) make a determination regarding the reviewers’ 

objectivity. Program offices will consult with the OGC Ethics Division when 

assistance is needed in determining if a significant connection or significant 

identification exists. All related documentation, decisions, and final course of action 

will be filed in the official competition file.” 

2. If such factors are not involved in the competition in a way that would cause a 

reasonable person to question the objectivity of a peer reviewer associated 

with or connected to one methodology or viewpoint, program offices may 

state within the ATRP that:

“Specific teaching methodologies, research methodologies, pedagogical 

viewpoints, and/or philosophical viewpoints are not involved in this competition in a 

way that would cause a reasonable person to question the objectivity of a peer 

reviewer associated with or connected to that methodology or viewpoint.” 

C. Guidance – Reserved

D. Other Pertinent Information – Reserved
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3.3 Developing, Maintaining, and Closing the Grant Program 

Competition File

A. Policy

1. Program officials designate specific program staff to be responsible for the 

following required actions in the life cycle of the Grant Program Competition 

File (Competition File):

a. Create and manage the Competition File (note: typically, the program 

official should designate the competition manager.),

b. Close the Competition File once its cohort of awarded grants has been 

closed, and

c. Archive the Competition File in accordance with Departmental Directive

ACSD-OCIO-012, Records and Information Management Program; 44 

U.S.C. Chapters 21, 29, 31, and 33; and 36 C.F.R. Chapter XII, 

Subchapter B (note: typically, the program official should designate the 

program office’s records liaison officer.).

2. Program offices create, maintain, and archive their Competition Files in 

compliance with ACSD-OCIO-012; 44 U.S.C. Chapters 21, 29, 31, and 33; 36

C.F.R. Chapter XII, Subchapter B; and applicable ED Comprehensive 

Records Retention and Disposition Schedules and National Archives and 

Records Administration General Records Schedules (GRS).

3. Competition Files are maintained in either the grants management system or 

the Office 365 OneDrive.8

4. Program officials follow the requirements in the “Grant Program Competition 

File SOP” (Competition File SOP) to ensure completeness and proper 

management of the Competition File, except where the requirements and 

needs of a competition dictate otherwise. (The Competition File SOP is 

available at Documents and Forms Referenced in the Handbook for the 

Discretionary Grant Process).

5. All duties assigned to ED employees to implement this policy are to be 

consistent with their respective position descriptions.

8 If a program official determines that a program office is unable to use the grants management system

to maintain the Competition Files as noted in the Guidance section then the program office’s records 

liaison officer, as the position is described in Directive OM 6:103, must, on an annual basis, inform, in 

writing, ED’s records officer of the determination and the exact location of the grant program competition 

files in Office 365 OneDrive or in any succeeding electronic platform designated by ED.
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B. Procedures

1. To ensure the Competition File is properly created, managed, and closed, 

each grant program follows the Competition File SOP, which identifies the 

following:

a. The types of documents that should be included in the Competition File;

b. The staff position responsible for creating and managing the Competition 

File;

c. The staff position that reviews the Competition File (file reviewer9) to 

ensure it is complete; and

d. The staff position responsible for archiving the Competition File.

2. The “Grant Program Competition File Review Checklist” (the Checklist) is 

completed within 45 calendar days of all awards having been made to confirm 

that the Competition File has been reviewed for completeness, and for the 

timely and accurate filing of all Competition File documents. (the Checklist is 

available at Documents and Forms Referenced in the Handbook for the 

Discretionary Grant Process).

3. The file reviewer completes and signs the Checklist and adds it to the 

Competition File in accordance with step 4 of the Competition File SOP.

4. Any legal documents governing the competition, as well as applicable10

correspondence, including emails related to the competition, is incorporated 

into the Competition File as each stage of the process is completed, per the 

Competition File SOP. The list below includes the standard documents for 

most Competition Files.

a. Relevant sections from the authorizing statute;

b. Program regulations, if applicable;

c. Federal Register Notices (such as Notice of Proposed and/or Final 

Priorities, Notice Inviting Applications, Common Instructions for Applicants 

to Department of Education Discretionary Grant Program, notices 

extending application deadline dates, correction notices);

9 A program office’s “file reviewer” must be a program official or executive officer. The “file reviewer” role 

should not be carried out by a person who was responsible for creating and managing the Competition 

File as a matter of internal control. 10Grant programs vary across ED based on statute, regulations, and the programs’ purpose; therefore, 

required documents for the Competition File will also vary.
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d. Any legal opinions or policy decisions (such as conflict of interest actions, 

ethics waivers, memoranda concerning the design of the competition) 

relevant to the competition, if applicable;

e. Application package;

f. The Office of Communication and Outreach (OCO) justification for the 

Intergovernmental Review comment period waiver or for shortening the 

deadline;

g. Pre-application technical assistance and outreach, including presentation 

materials from webinars and FAQ documents, if applicable;

h. ATRP;

i. Application log(s) and list of applications screened out as being ineligible 

along with correspondence to the applicant identifying the reason for the 

non- eligibility determination; 

j. List of peer reviewers;

k. Peer reviewer agreements;

l. Evaluations, by the peer reviewers, of the application review process, if 

applicable;

m. Documentation of conflicts of interest, if any peer reviewers have been 

replaced, or of any difficulties with specific peer reviewers, if applicable;

n. Records of any discussions between program offices and specific peer 

reviewers or panels that influenced the outcome of the review (see the 

section Peer Review Scoring and Quality Control), if applicable;

o. Grant Funding Slates (see the Grant Funding Slate Template) for all 

pertinent information that is required to be addressed and included;

p. Documentation of risk assessments and the results of the risk 

assessments; 

q. Documentation of any rejection of the Grant Funding Slate 

recommendations and copies of amended Grant Funding Slates, if 

applicable;

r. Documentation of any funding decisions unique to applications, if 

applicable;
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s. Documentation that the committed funding amounts between Oracle 

Financials (OF) and the grants management system are properly posted 

in OF for each grantee;

t. Any additional competition documents required per statute, program 

regulations, or program office policy, if applicable; and

u. The completed Checklist.

5. The Competition File is securely stored11 until all the grants awarded under 

the competition have been closed out.

6. The Competition File is closed and archived when all grants made under the 

same competition are closed and archived.

a. If the Competition File is maintained in the grants management system, no 

action is needed for closure.

b. If the Competition File is maintained in Office 365 OneDrive, the individual 

responsible for the file closure runs a closeout report from the grants 

management system showing all awards from the competition were 

closed. A screenshot of the report is included in the Competition File 

which is then closed and archived.

C. Guidance

1. Program offices should maintain their Competition Files, using the 

Competition File function, available in the grants management system. If a 

program official determines that the grant program cannot use the grants 

management system, due to system limitations, then program offices 

maintain their Competition File in the Office 365 OneDrive (or in any 

electronic platform succeeding the Office 365 OneDrive that is designated by 

ED).

D. Other Pertinent Information 

1. The Departmental Directive ACSD-OCIO-012, Records and Information 

Management Program is located at Numbered List of ACS Directives and 

Handbooks 

3.4 Receiving and Screening Applications

11 If transitioning from one file site to another, including a paper file repository, program offices should 

ensure the plan for the transition minimizes transition time and is consistent in its process to avoid having 

more than one location for the Competition File.
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3.4.1 Applications Submitted Electronically

A. Policy

1. Program offices allow grant applicants to submit their applications 

electronically, in accordance with The Government Paperwork Elimination 

Act, P.L. 105-277, Title XVII. The Act requires that all Federal agencies 

provide their customers the capability to conduct business electronically.

2. ED participates as a partner in Grants.gov site and discourages paper 

applications.

3. Program offices designate Grants.gov for applicants to use when submitting 

electronic applications to ED, unless a grant program is unable to use 

Grants.gov (e.g., fellowships).

4. Electronic applications are submitted by no later than 11:59:59 p.m., Eastern 

Time, on the day applications are due for a grant competition, unless the 

competition does not follow the Common Instructions. 

B. Procedures

1. In the NIA for the grant competition, program offices:

a. Identify Grants.gov as the application submission system, unless it is an 

ED program that cannot use Grants.gov. 

b. Address how an application package can be obtained by referencing the 

Common Instructions, which provides instructions for prospective 

applicants on obtaining application packages, and application submission 

requirements.

2. Program offices do not accept a faxed, emailed, or mailed application under a 

grant competition requiring electronic submission, unless doing so is 

specifically authorized in the Federal Register NIA for the grant competition.

3. If electronic submission is not possible (e.g., no access to the Internet), 

applicants must follow the Submission of Paper Applications instructions in 

the Common Instructions. 

C. Guidance – Reserved

D. Other Pertinent Information

1. In addition to establishing the application submission deadline for the 

competition and the basis for determining whether an application has been 
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submitted in a timely manner, ED uses the NIA to establish the type of 

applications that ED considers for a competition.

3.4.2 Applications Submitted Via Grants.gov

A. Policy

1. Program offices ensure applicants submit their applications electronically in 

Grants.gov, unless electronic submission is not possible, following the 

submission requirements in the Common Instructions. 

2. Program offices, if it’s reported that a technical issue with Grants.gov

prevented the submission of an application, verifies the issue before settling.

B. Procedures

1. Applications submitted via Grants.gov are handled as follows:

a. Applications must be fully uploaded and be date-and time-stamped by the 

Grants.gov system no later than 11:59:59 p.m., Eastern Time, on the 

application deadline date, unless otherwise specified in the Federal 

Register NIA for the grant competition.

1) Grants.gov automatically generates an acknowledgement of the 

receipt of the applicant’s application in the form of a screen 

confirmation on the Grants.gov website, and via email from Grants.gov

with a Grants.gov tracking number.

2) The Grants.gov confirmation does not mean the applicant complied 

with all ED’s application requirements (e.g., if the applicant submitted 

an Excel table instead of a PDF or Word document).

b. ED pulls the application from Grants.gov, and the grants management 

system verifies whether the submission to Grants.gov was timely and 

sends an email to the applicant.

1) The acknowledgement receipt from ED indicates the date and time 

Grants.gov received the application, as well as the PR/Award number 

assigned to the application.

c. If the applicant submits their application via Grants.gov after the 

submission deadline, Grants.gov still generates a confirmation that the 

application was received and provides a Grants.gov tracking number.

1) The grants management system automatically generates an email 

notification indicating that the application is rejected because it was 

submitted late. It also marks the application as late in the database.
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d. If an applicant is prevented from electronically submitting their application 

by the application deadline due to technical problems with Grants.gov, the 

applicant follows the “Application Deadline Date Extension in Case of 

Technical Issues with the Grants.gov System” section of the Common 

Instructions. 

e. After the applicant communicates with the Grants.gov Support Center, the 

applicant contacts the person listed in the FOR FURTHER 

INFORMATION CONTACT section of the NIA to report that technical 

problems were experienced while applying via Grants.gov, as described in 

the Common Instructions. If this occurs, program offices:

1) Collect additional information from the applicant (such as the 

Grants.gov Support Desk case tracking number, a description of the 

problem, and a timeline of when the technical problem occurred);

2) Contact the grants management system staff in the Business Systems 

Support Division (BSSD) with this information to confirm the validity of 

the technical problem; and

3) If the technical problem is verified by BSSD as having affected the 

applicant’s ability to submit their application on time via Grants.gov, 

program offices grant an extension until 11:59:59 p.m., Eastern Time, 

the following business day to enable the applicant to transmit their 

application electronically (see the “Application Deadline Date 

Extension in Case of Technical Issues with the Grants.gov System” 

section of the Common Instructions).

f. ED discourages paper applications; however, if electronic submission is 

not possible (e.g., the applicant does not have access to the Internet), the 

applicant must provide a written statement of its intent to submit a paper 

application. The Common Instructions require that:

1) The applicant sends it written statement no later than two weeks 

before the application deadline date (14 calendar days, or, if the 14th

calendar day before the application deadline date falls on a Federal 

holiday, then the next business day following the Federal holiday).

2) If the applicant mails its written statement to the ED it must be 

postmarked no later than two weeks before the application deadline 

date.

3) The applicant’s written statement is sent to the person listed in the 

FOR FURTHER INFORMATION CONTACT section of the competition 

NIA.
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C. Guidance – Reserved

D. Other Pertinent Information – Reserved

3.4.3 Extending Application Deadline Dates for Exceptional 

Circumstances

A. Policy

1. Program offices consult with their program attorney about the feasibility of 

extending deadline dates in instances of exceptional circumstances 

discussed under the Guidance section.

B. Procedures – Reserved

C. Guidance

1. Program offices may extend the deadline date for applications, when the 

following exceptional circumstances occur:

a. The President has issued a natural disaster declaration and the Secretary 

determines that the disaster interfered with applicants’ ability to submit 

applications by the deadline, (such natural disaster declarations can be 

verified at the following Federal Emergency Management Agency website: 

Disasters - FEMA.gov);

b. The Governor of a State has issued a declaration that a natural disaster 

occurred in their State.

c. Other circumstances that are beyond the applicants’ control occur that 

prevent the timely submission of applications (e.g., the original Federal 

Register NIAs, or other published documents, such as amendments to 

NIAs, ED.gov, gave incorrect or misleading information that had a 

significant effect on the application process).

2. Generally, a natural disaster is considered an exceptional circumstance when 

it is the subject of a natural disaster declaration by the President and when 

the Secretary determines that the disaster interfered with a grant applicant’s 

ability to submit required applications or grant-related materials by 

established due dates.

3. A Governor’s declaration of a natural disaster may also be considered an 

exceptional circumstance, and program offices may verify a declared disaster 

through the applicable State government websites.
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D. Other Pertinent Information

1. The team in BSSD modifies the synopsis in Grants.gov to reflect the 

application deadline extension.

3.4.4 Standards for Reviewing Applications

A. Policy

1. Program offices conduct initial eligibility reviews on all applications in 

accordance with EDGAR § 75.216. However, comprehensive reviews for 

eligibility are conducted on the highest scoring applications.

2. An application determined to be ineligible prior to the start of the competition 

review is not required to be accepted for review and scoring;

a. Program officials have the authority to override this decision and have the 

application reviewed and scored by the application reviewers, if an 

application is determined to be ineligible prior to the start of the 

competition peer review by program staff.

3. Program offices screen-out duplicate applications after consulting with the 

program attorney. In most cases, program offices accept and review the last 

timely submission of an application.

B. Procedures

1. Program offices, in accordance with EDGAR § 75.216, ensure applications 

are only reviewed for funding if:

a. The applicant is eligible;

b. The applicant follows all the procedural rules that govern submitting the 

application;

c. The application contains the information required under the program; and

d. The proposed project can be funded under the authorizing statute and 

implementing regulations, if any, of the program.

2. If an application is determined to be ineligible according to above Procedures 

item 1, program offices provide a notification specifying the reason(s) why the 

application is ineligible as soon as possible after the determination is made 

(see EDGAR § 75.218).

a. Program offices keep a copy of the ineligible application and associated 

documents for 3 years after rejection.
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3. If program offices determine an application to be ineligible, they choose one 

of the five ineligibility options listed in the grants management system to 

indicate a status of “ineligible.” The five content ineligibility options in are:

a. Not Applicable (NA) (e.g., an application was erroneously submitted under 

one program but should have been submitted under another program);

b. The applicant is not eligible (e.g., the applicant is not an eligible entity 

under the eligibility requirements of the program);

c. The applicant did not comply with all the procedural rules that govern the 

submission of the application (except as otherwise noted in the Common 

Instructions the application did not comply with the submission deadline 

requirements);

d. The application does not contain the information required under the 

program; or

e. The proposed project cannot be funded under the authorizing statute or 

implementing regulations for the program.

4. If the NIA establishes a maximum award amount, ED may still review 

applications that request awards in excess of that amount, but it may not 

make an award in excess of the established maximum. An applicant that 

proposes a budget that exceeds the maximum award amount, but scores in 

the funding range, may receive a grant only if it can reduce its budget to the 

maximum award amount without changing the scope and objectives of its 

proposed project.

5. If program offices cannot determine, after the initial screening, whether an 

applicant or its proposed application meets the eligibility requirements for the 

competition, they immediately consult with the program attorney to determine 

eligibility.

a. Program offices accept the application for review and scoring by the 

competition peer reviewers while a definitive eligibility determination is 

made in consultation with the program attorney.

b. If, after consultation with the program attorney, and prior to the start of the 

peer review, a program deems the application ineligible, then the 

application does not have to be reviewed.

6. If program offices discovers that an application should not have been 

reviewed under EDGAR § 75.216, during or after the application review 

process has been completed, the application is still rejected.
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7. If an application is rejected, the competition manager notifies the applicant as 

soon as possible after the decision to reject is made and before grants are 

awarded under the competition.

C. Guidance

1. Consultation with the program attorney is done immediately to ensure enough 

time should OGC determine that the application should be peer reviewed 

when program offices are unable to determine eligibility after initially 

screening (see Procedures item 5).

2. Program offices should not determine that an application is ineligible when 

unsure about making this determination since it could result in an eligible 

application not being reviewed during the review process. A problem of this 

type, (i.e., not reading and scoring an eligible application during the peer 

review process) is more difficult to correct than having an ineligible application 

reviewed. In the former case, special arrangement needs to be made to have 

the application reviewed, and in the latter case, the application is simply 

removed from consideration for funding after it is found to be ineligible.

D. Other Pertinent Information

1. The grants management system automatically lists all received applications 

for new grants as “eligible.” For this reason, it is necessary for programs to 

conduct initial eligibility screens of all new applications.

3.5 Peer Reviewers

3.5.1 One Percent Set-Aside for the Peer Review

A. Policy

1. The Department of Education Organization Act (DEOA) provides that the 

Department may not use more than one percent of the funds appropriated for 

any ED discretionary grant program to pay the expenses and fees of nonFederal experts (peer reviewers) necessary to review applications and 

proposals for such funds (20 U.S.C. § 3462(b)).12

12 20 U.S.C. § 3462(b)(2) reads, in full, “notwithstanding any other provision of law, the Secretary may use 

not more than 1 percent of the funds appropriated for any education program that awards such funds on a 

competitive basis to pay the expenses and fees of non-Federal experts necessary to review applications 

and proposals for such funds.” The term used repeatedly by Congress in the legislative history of this 

provision is “field readers,” indicating the set-aside was to pay for experts in the field to review and score 

applications. Please see https://www.congress.gov/bill/103rd-congress/house-bill/1804 for more 

information.
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2. Not all ED discretionary grant programs utilize the one percent set-aside 

reservation in the DEOA; this section only applies to those programs utilizing 

it.13

B. Procedures

1. Program offices utilizing the one percent set-aside reservation ensure that 

their logistical contracts for running competitions do not propose to fund 

items that are not reasonably tied to the expenses and fees of nonFederal experts (i.e., peer reviewers) necessary to review applications and 

proposals for such funds.

2. Program offices develop draft contractual statements of work (SOW) and 

other contracting materials that propose tasks to be completed by the 

contractor and funded using the one percent set-aside reservation.

3. Program offices work with their assigned contracting officer to ensure that 

SOW is correct and consult with the program attorney when they are 

unsure whether a task or activity can be appropriately funded by the one 

percent set-aside reservation.

4. Program offices choose alternative sources of funding when it is 

determined that the specific task or activity cannot be funded using the 

one percent set-aside reservation.

C. Guidance

1. In general, tasks or activities that are connected to the Peer Review process 

are allowable, whereas other activities, which may be connected to the 

operation of the grant competition, but are not connected to the Peer Review 

process, are unallowable.

2. The following examples are intended to illustrate some possible tasks and 

activities that can and cannot be funded using the statutory authority of the 

one percent set-aside:

a. Examples of Allowable Activities (can be funded out of the one percent 

set- aside):

1) Paying and arranging for peer reviewer honoraria or compensation;

13 The one percent set-aside reservation is not available to programs that have a separate authorization to 

pay the fees and expenses of non-Federal experts (see 20 U.S.C. § 3462(b)(2)). Programs with their own 

authorizations to support the costs of conducting competitive grant competitions would follow their own 

program-specific statutory authority. Tasks and activities that cannot be funded under the one percent 

set-aside may be allowable under other funding sources, such as S&E. funds. However, a task or activity 

that is inherently governmental, cannot, under any circumstances, be performed by a contractor.
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2) Peer reviewer lodging, travel, and per diem costs associated with onsite peer review, such as reserving a meeting or hotel space for peer 

reviewers to screen and discuss applications;

3) Paying and arranging for costs associated with virtual peer review, 

such as mailing applications and establishing and scheduling video or 

phone communications;

4) Collecting and processing peer reviewer information, including 

disclosure forms, conflict of interest forms, and payment forms;

5) Providing logistical support for peer reviewer training webinars;

6) Distribution and assignment of applications to peer reviewers, such as 

by creating an internal website for the distribution of applications for 

use by the peer reviewers;

7) Collection and initial review of peer reviewer TRFs; and

8) Responding to questions from peer reviewers on matters such as basic 

logistical questions and referring all questions of judgment or of a 

substantive nature to the program office.

b. Examples of Unallowable Activities (cannot be funded out of the one 

percent set-aside):

1) Pre-screening applications for technical elements and making 

preliminary recommendations as to eligibility;

2) Preparing or transmitting applicant eligibility notifications;

3) Organizing information to be used in preparing the slate memo or 

drafting the slate memo;

4) Providing logistical support for pre-application technical assistance 

webinars for prospective applicants;

5) Responding to questions from prospective applicants on matters such 

as application deadlines; and

6) Updating or maintaining the grant competition’s public-facing website 

(including posting competition notices, technical assistance webinars, 

application FAQs and successful applications).
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D. Other Pertinent Information

1. The issues concerning the one percent set-aside are related to, but separate 

from, the requirement that contractors not perform any inherently 

governmental functions. For that reason, program officers should also read 

below “Inherently Governmental Functions and Contractors” and be familiar 

with the restrictions regarding contractors performing inherently governmental 

functions.

3.5.2 Inherently Governmental Functions and Contractors

A. Policy

1. Program offices are diligent in that contractors must not perform inherently 

governmental functions (see Other Pertinent Information for the definition of 

“Inherently Governmental Functions”).

2. Applicability. This section applies ED employees overseeing contractors that 

carry out tasks related to the administration of a discretionary grant. All ED 

employees are authorized to carry out inherently governmental functions as 

appropriate and within the scope of their positions.

B. Procedures

1. For situations where it is possible that a contracted function could lead to a 

contractor exercising an inherently governmental function, program offices, in 

consultation with CAM and the program attorney, create a protocol that 

establishes the following:

a. A description of the role of the contracted function detailing routine, 

ministerial, and internal roles for the contracted function.

b. A description of how a contractor should avoid exercising an inherently 

governmental function (e.g. who to defer to/contact when an issue arises, 

what functions are considered inherently governmental and therefore 

prohibited, specified range of acceptable decisions or conduct by the 

contractor, etc.).

c. A description of how the contractor will receive notification regarding their 

role and responsibilities.

d. A description of how program offices will provide meaningful oversight to 

ensure the contractor’s activities do not expand to include inherently 

governmental functions and are not performed in ways not contemplated 

by the contract to become inherently governmental.
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2. This protocol may appropriately be included in a contractual Statement of 

Work (SOW) or in the Application Technical Review Plan (ATRP).

3. When questions arise, program offices consult with CAM and the program 

attorney prior to deciding whether a task or activity is inherently 

governmental.

C. Guidance

1. Examples. The following table are some examples of typical discretionary 

grant functions that may or may not be inherently governmental and that 

program offices should consider in preparing logistical or technical assistance 

contracts:
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Contracted 

Function

Not inherently governmental (may be 

carried out by contractors)

Inherently governmental function 

(may not be carried out by

contractors)

Peer review panel 

monitors14

Convening and monitoring 

discussions among peer reviewers; 

coordinating the assembly of the 

panel; organizing documents; 

reviewing Technical Review Forms 

(TRFs) to ensure peer reviewer 

feedback is grammatically correct or 

scores are correctly totaled; 

preliminary review of TRFs to ensure

peer reviewer scores are adequately 

justified

Leading or moderating discussions 

among peer reviewers; interpreting 

program requirements to peer 

reviewers; final review and approval 

of TRFs to ensure peer reviewer 

scores are adequately justified; 

resolving any substantive or 

judgment issues

Application 

screening

Screening for technical elements 

such as existence of required 

attachments; preliminary

recommendations with explanations 

as to eligibility

Final decisions as to whether the 

applicant meets an absolute priority 

or is an eligible entity

Slate development Assembling information; collating 

scores; preparing materials for public 

web posting or 508 compliance; 

making sure budget calculations are 

correct; drafting project abstracts on

basis of material included in 

applications

Preparing the grant slate; 

recommending applicants for 

funding; budget review of allowable 

costs

Logistical support Organizing and providing logistical 

support to the pre-application 

technical assistance webinar; 

creating a draft technical assistance 

webinar for ED review; directing

applicants to existing program 

application guidance

Leading a pre-application technical 

assistance webinar; conducting a preapplication technical assistance 

webinar; answering applicants’ 

questions

Grantee 

monitoring

Assembling information for 

monitoring reports to be reviewed and 

followed-up by ED; collecting and

aggregating APR, IPR, or other grant 

performance information

Finalizing monitoring reports and 

program findings without explicit ED 

review and approval. Retaining

records of monitoring, including the 

grantees’ responses.

Technical 

assistance (TA) to 

grantees

Providing TA on best practices and 

implementation of grants consistent 

with established ED practices; 

presenting possible options for 

grantees to use based on ED-issued

interpretations of existing law, 

regulations, and guidance

Interpreting law or regulations; 

directing grantees to implement a 

corrective action based on a 

contractor’s own interpretations of 

existing law, regulations, or guidance

14 Importantly, the differences between a panel monitor “convening and monitoring discussions” and 

“leading or moderating discussions” among peer reviewers is the exercise of the panel monitor’s 

discretion during the panel. Program offices contracting out panel monitors develop appropriate protocols 

and training to ensure contracted panel monitors will only perform routine and ministerial functions and 

not exercise their discretion in leading or moderating panel discussions.
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D. Other Pertinent Information

1. Definition. An inherently governmental function is a function that “is so 

intimately related to the public interest as to require performance by Federal 

Government employees.” (Section 5(2) of the Federal Activities Inventory 

Reform Act of 1998 (FAIR Act)). A function that is determined to be inherently 

governmental may not be contracted and must be performed by employees of 

the Federal Government.

2. General. In general, an inherently governmental function is one that requires 

the agency to exercise discretion in decision-making; a function that is not 

inherently governmental is one that is routine and ministerial (i.e. an act or a 

function that conforms to an instruction or a prescribed procedure)

3. The issues concerning inherently governmental functions are related to, but 

separate from, the use of funds under the one percent set-aside reservation 

used by most, but not all, discretionary grant programs to fund competition 

logistical contracts. For that reason program officers should also read One 

Percent Set-Aside for Peer Review and become familiar with the restrictions 

on the use of funds from the one-percent set aside.

3.5.3 Factors to Consider in Recruiting and Selecting Peer Reviewers

A. Policy

1. Program offices use experts to evaluate the applications submitted for funding 

under a grant competition (see EDGAR 75.217a).

2. Program offices solicit experts to serve as reviewers for a grant competition 

without regard to race, color, national origin, gender, age, or disability.

3. Program offices use outside reviewers (not employees of the Federal 

government) to provide independent perspectives and practical expertise to 

the extent that doing so enhances a fair and competitive review process (see 

EDGAR 75.217(2)).

a. Program offices provide reasonable accommodations, if needed, to all 

individuals selected to serve as peer reviewers.

B. Procedures

1. Program offices, in soliciting experts to serve as reviewers for a grant 

competition, provide a notice that includes a statement that ED solicits 

reviewers without regard to race, color, national origin, gender, age, or 

disability. The notice also indicates that ED will provide reasonable 

accommodations for an individual with a disability, so that the individual is 

able to participate in the review process.
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2. The use of outside reviewers is preferred; however, there are times when 

legitimate program management considerations may necessitate a departure 

from the practice of using outside reviewers. For those competitions where 

reviewers internal to the POC (but not to the specific program) are used, 

program offices include a justification in the ATRP.

3. When program staff reviews applications, they do not review applications 

submitted under the grant programs they administer, unless allowed by 

statute or Congress mandates funding a specific applicant or a group of 

applicants (see the section Directed Awards (Earmarks)).

4. If applications are reviewed by a panel of reviewers and more than one panel 

is convened, the number of reviewers on each panel is fixed and, unless 

exceptional circumstances occur, cannot vary between panels.

5. Each reviewer reviews all applications assigned to the panel unless 

circumstances lead to removal or replacement of a reviewer. When a 

reviewer is replaced, program offices follow the policies and procedures in the 

section Replacement of Reviewers During the Review before proceeding.

6. Program offices, when providing peer reviewer compensation, pay travel and 

per diem expenses in accordance with the Federal Travel Regulations. 

C. Guidance

1. The panel of experts used to evaluate grant applications typically consists of 

three or more experts, but may include other members in accordance with 

applicable laws or regulations, or as justified in the ATRP (see the section 

“Developing and Approving the Application Technical Review Plan”).

2. When considering competition peer reviewer compensation, reviewers who 

are not Federal employees generally receive reasonable compensation for 

their services. Reviewers may also volunteer their service without 

compensation.

D. Other Pertinent Information

1. EDGAR § 75.217 affords ED the flexibility to use peer reviewers who are not 

employees of the Federal government.

2. Federal Travel Regulations are found at: Federal Travel Regulations - GSA. 

2. 
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3.5.4 Recruiting Peer Reviewers for the Reviewer Database

A. Policy

1. Program offices recruit peer reviewers with extensive background and 

expertise in the subject area of the competition, to the maximum extent 

possible.

B. Procedures – Reserved

C. Guidance

1. Program offices should consider using the information in the common, EDwide the grants management system database15 of peer reviewers to identify 

potential reviewers and to get an assessment of peer reviewers’ previous 

performance.

2. When considering peer reviewers for participation in their panels, competition 

managers should consider consulting with other ED staff (or employees in 

other agencies) who have previously worked with peer reviewers, to assess 

reviewers’ skills and competence in scoring applications reliably.

3. When program offices receive inquiries from other ED staff regarding peer 

reviewers, they should respond as if the request is urgent so that reviews or 

other performance matters are addressed timely and appropriately.

4. The suggested process for recruiting reviewers for the reviewer database is

as follows:

a. Program offices should recruit persons from as many sources as possible 

and who are highly-qualified in areas pertinent to the competition.

b. Program offices may use a prospective reviewer’s resume, curriculum 

vitae, or a standard form to determine the reviewer’s qualifications.

c. The methods for recruiting individuals for the reviewer database include:

1) Advertisements in appropriate publications, including but not limited to 

the Federal Register, journals, newspapers, and the program’s 

website. For these recruitment efforts, program offices should include 

information on how to register in the GMS peer reviewer database 

found in the course, Using GMS and Completing Technical Review 

15 The information in the reviewer database is protected under the Privacy Act of 1974, as amended in 5 

U.S.C.§ 552a, and ED employees do not disclose sensitive information from the database. When unsure 

of what information may or may not be released, staff should contact their program attorney for guidance.
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Forms, located in the Introduction to Being an Effective Peer Reviewer

computer-based training course. 

2) Letters of request to key individuals (such as college or university 

deans, heads or prominent members of educational research 

institutions and professional associations, or private and public-school 

officials);

3) Contacts with members of the educational community, professional 

associations, and current or former reviewers; and

4) Requests to employees of ED or other Federal agencies (see the 

“Reviewers Who Are Federal Employees Rules” section).

d. Program offices establish and maintain a peer reviewer database that 

identifies peer reviewers who are willing and available to review 

applications.

D. Other Pertinent Information – Reserved

3.5.5 Selecting Reviewers for a Reviewer Roster

A. Policy

1. Program offices ensure that potential reviewers do not have conflicts of 

interest with the applications to be reviewed.

2. Program offices ensure that potential reviewers have not been debarred or 

suspended under the Federal rules for debarments and suspensions for 

contracting and non-contracting situations.

3. The decision to not select a potential reviewer based on an actual or possible 

conflict of interest is an inherently governmental function and therefore made 

only by program offices.

4. After reviewers are selected, program offices submit the reviewer roster for 

each competition to the program official for review and approval. The program 

official approves the reviewer roster, to maintain a fair and competitive review 

process, and includes it as part of the grant program competition file prior to 

beginning the review.

B. Procedures

1. Program offices that choose to use the Grants Management System (GMS)

database of peer reviewers select reviewers to form the reviewer roster for a 

grant competition.
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2. Program offices compare the entire list of applications for the grant 

competition to the list of potential reviewers to identify potential conflicts of 

interest before making final reviewer selections and before the start of the 

panel review process.

3. All peer reviewers are screened in SAM.gov in order to ensure none have 

been excluded, debarred, or suspended. No individuals who have been 

excluded, debarred, or suspended may serve as a peer reviewer.

4. Application review logistical contractors may initially screen the names of 

reviewers to be chosen; however, only program offices make the decision to 

not include a potential reviewer.

5. Program offices determine whether a reviewer has a potential conflict of 

interest and makes the decision to not include this reviewer.

6. Program offices, after reviewers are selected, submits the reviewer roster for 

each competition to the program official (not the Principal Officer) for review 

and approval.

7. Program offices, after the program official approves the reviewer roster, 

includes it in the grant program competition file based on deadlines 

established in the section, Developing, Maintaining, and Closing the Grant 

Program Competition File. 

8. Program offices ensure that all selected peer reviewers, even those reviewers 

that will not receive compensation, have obtained a Unique Entity Identifier 

(UEI) number and registered in SAM.gov. 

C. Guidance

1. To assist in identifying reviewers who may have a conflict of interest, program 

offices should consider using the “Questions for Application Reviewers on 

Conflict of Interest and Other Factors That Might Affect Objectivity” guide 

available at the following link: Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process. 

D. Other Pertinent Information – Reserved

3.5.6 Using Reviewers in Consecutive Application Review Cycles

A. Policy

1. Program offices limit the regular use of the same reviewer for a program by 

not using the same reviewer for more than three consecutive application 

cycles. Regular use of the same reviewer may result in that reviewer 
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becoming too familiar with both the program and its applicants, thereby losing 

his or her ability to provide an objective assessment.

B. Procedures

1. Program offices analyze their pool of peer reviewers to determine the level of 

recurrence of each reviewer.

2. If program offices are unable to recruit enough highly qualified reviewers to 

comply with the goal of limiting application reviewer familiarity, they obtain a 

waiver from the Program Official to use an application reviewer for more than 

three consecutive application cycles.

a. Program offices limit peer reviewer familiarity by:

1) Not using a peer reviewer in the same program, (i.e., a Federal 

assistance program with an assigned unique ALN) for more than three 

consecutive application cycles; or

2) During each application cycle, substituting at least 1/3 of the reviewers 

used in the previous year with new reviewers.

3) Exercising one of the options listed above does not apply to those 

grant programs that use standing panels (i.e., review panels to which 

reviewers have been permanently appointed, or appointed on a 

rotating basis, to a one-year or for multi-year terms) when the tenure of 

the members of those standing panels is longer than three years.

4) Approved waivers to use reviewers for more than three consecutive 

application cycles are included in the grant competition file.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

3.5.7 Packages for Peer Reviewers

A. Policy

1. Program offices provide peer reviewers with application reviewer packages.

B. Procedures

1. Program offices prepare and provide to each reviewer an application reviewer 

package prior to the application review process.
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2. Peer reviewer packages are only sent to reviewers who: are approved in 

accordance with the procedures in the section, Selecting Reviewers for a 

Reviewer Roster. 

3. The peer reviewer package contains the following; however, program offices 

should tailor the package to the specific needs of the review process for their 

program:

a. Peer reviewer letter (describes the logistics of the review process);

b. Grant program application package(s), including the NIA;

c. List of applications to be reviewed in the competition;

d. Technical Review Forms (TRFs);

e. Either a “Department of Education Agreement for Grant Application 

Reviewers Who Serve without Compensation” or a “Department of 

Education Agreement for Grant Application Reviewers Who Receive 

Compensation”, whichever is applicable. The agreements are available at: 

Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process; 

f. Certifications regarding lobbying; and

g. Evaluation form to be completed by each non-Federal reviewer, at the 

conclusion of the review, regarding the quality of the review process.

C. Guidance

1. To the extent possible, program offices should prepare and furnish to each 

peer reviewer a reviewer package at least one week in advance of the 

application review process to provide reviewers enough time to review the 

application reviewer package in advance of the review process.

D. Other Pertinent Information – Reserved

3.5.8 Qualifications and Training for Managing a Grant Competition

A. Policy

1. The Competition Manager is the ED staff person responsible for overseeing 

the entire discretionary grant competition and provides the direction and 

guidance for all review panels and staff working with the panels conducted 

under the competition.
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2. Program Officials include the name of the Competition Manager in the ATRP, 

if possible.

3. The Competition Manager possesses the following qualifications and skills:

a. Knowledge of EDGAR, the Handbook, and other documents that describe 

the proper procedures to follow managing a discretionary grant 

competition;

b. An understanding of the program to be competed, including:

1) The program statute and any program-specific regulations;

2) The NIA, especially the priorities, requirements, and selection criteria;

3) The application package and any application FAQs; and

4) The expertise peer reviewers need to have to perform their function 

effectively;

c. The appropriate access and ability to use GMS, including e-Reader;

d. Ability to apply the program regulations and requirements, as identified in

the NIA, to the peer review process;

e. An understanding of the ATRP and ED’s peer review process, including:

1) How the ATRP is used during the peer review process (e.g., following 

how the ATRP conveys that conflicts of interest will be addressed, how 

scoring ties will be addressed, etc.);

2) Roles and responsibilities for ED staff, peer review logistical 

contractors, and peer reviewers (see the sections Roles and 

Responsibilities in the Review Process and Inherently Governmental 

Functions and Contractors); 

3) The importance of peer reviewer scores and evaluative comments 

supporting the scores;

a) Strong organization, communication, dispute resolution, personnel 

management skills, and project management skills; and

b) Ability to clearly communicate peer review requirements and 

procedures to individuals assigned positions (e.g., panel monitors, 

peer reviewers, and contractors) in the peer review process.
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B. Procedures

1. Program officials require Competition Managers to take the Grant 

Competition Manager course which includes detailed information of the 

duties, skills, and necessary qualifications.

a. Program officials require a Competition Manager to work with a mentor, 

who is an experienced Competition Manager, when he/she is not able to 

complete the required class prior to the start of the competition to be 

managed.

2. Competition Managers identify and discuss any potential conflicts of interest 

among the competition’s peer reviewers with their program official and the 

OGC ethics attorney, if applicable.

3. The duties of a Competition Manager, include, but are not limited to, the 

following:

a. Ensuring fair treatment of all applications in the competition;

b. Ensuring the competition follows the requirements and procedures 

identified in the ATRP, including:

1) Establishing the peer review schedule;

2) Reviewing and approving all materials used to train peer reviewers;

3) Coordinating and leading the internal eligibility review of all 

applications;

4) Overseeing the distribution of applications to peer reviewers;

5) Training the peer reviewers, including panel chairs, and panel monitors 

and outlining the purpose of the review, how to score and comment, 

and how to use the grants management system (if applicable);

6) Monitoring the review process, application review logistical contractors 

(if applicable), and providing guidance to other ED staff, peer 

reviewers, and the application review logistical contractors (if 

applicable, see Inherently Governmental Functions section) involved in 

the process by overseeing the peer review panels and logistics of the 

competition;

a) If the Competition Manager is not the COR or program manager for 

the contract, discussions with the application review logistical 

contractor occur in consultation with the COR or program manager.
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6) Resolving any conflicts of interest and reviewer replacement issues 

that arise during peer review;

7) Overseeing the process to ensure reviewers’ comments are clear, 

objective, appropriate to the application, and correctly correspond to all 

selection criteria and competitive preference priorities, if applicable; 

and

8) Ensuring that reviewer comments support and align with the reviewers’ 

scores and are correctly entered into the grants management system

(if applicable);

4. Program officials document the qualifications possessed by the Competition 

Manager and any actions taken to fully qualify a Competition Manager, if 

applicable. Documentation (e.g., a memorandum from the program official 

that confirms that the Competition Manager is qualified and addresses any 

deficiencies through online training and/or working with a mentor) is included 

in the grant program competition file.

C. Guidance

1. The Competition Manager duties in the Procedures section are usually 

established in consultation with the program official.

2. Program officials may require the Competition Manager to ensure the 

completion of additional activities as assigned by the program official, such 

as:

a. Ensuring competition schedule dates are updated in the grants

management system, as needed;

b. Drafting the NIA and preparing the application package;

c. Leading public outreach and application technical assistance efforts;

d. Drafting the ATRP;

e. Coordinating and leading the internal budget review of all potential 

awardees;

f. Drafting the Grant Funding Slate for submission to the Principal Officer; 

and

g. Creating and maintaining the Grant Program Competition File.
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3. Program officials should consider having a pool of trained and experienced 

Competition Managers who would serve as mentors to new Competition 

Managers.

4. Competition Managers further their own professional development by 

identifying and participating in trainings and educational offerings to:

a. Gain knowledge and skills appropriate to lead the peer review process 

and responsibilities outlined by the program official;

b. Ensure that the principal office is conducting the peer review process in 

compliance with all applicable laws, regulations, and policies; and

c. Gain and improve an understanding of all aspects of their responsibilities.

5. Training topics available to Competition Managers to further their own 

professional development, as offered by GMPD, OGC, or other offices, may 

include:

a. Budget Review Process

b. Conducting a Risk Evaluation 

c. Risk Mitigation

d. Slate Development.

6. Competition Managers also participate in GMPD’s quarterly policy forums for 

ED staff. The policy forum provides a venue for informing ED staff about 

important grants-related information and for POCs to exchange information.

D. Other Pertinent Information – Reserved

3.5.9 Roles and Responsibilities in the Review Process

A. Policy

1. The following roles and responsibilities are required for the peer review 

process, and they are applicable to all ED peer reviews, regardless of 

whether the review is held on-site at a central location, conducted 

electronically, conducted by mail, conducted by teleconference, or by using a 

combination of these methods.

a. Competition Manager – See the section Qualifications and Training 

Needed to Run a Discretionary Grant Competition. 
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b. Panel Monitor – The individual who moderates or monitors discussions 

among peer reviewers. The duties of a panel monitor depend on whether 

the individual is an ED employee or a contractor; therefore, program 

offices refer to the section Inherently Governmental Functions and 

Contractors, when establishing responsibilities for this role. Some of the 

duties of an ED Panel Monitor can include:

1) Moderating discussions among peer reviewers.

2) Interpreting program requirements.

3) Preliminary or final review and approval of Technical Review Forms 

(TRFs) to ensure peer reviewer scores are adequately justified.

4) Answering procedural and administrative questions.

5) Ensuring that reviewers, within their assigned panels, adhere to the 

standards and expectations described in the “Application Reviewer 

Standards or Expectations” section.

6) Assigning reviewers and scheduling panels.

c. Some of the duties of a Panel Monitor who is a contractor can include:

1) Monitoring discussions among peer reviewers.

2) Convening panels and monitoring progress of assigned panel(s).

3) Preliminary review of TRFs to ensure scores are totaled correctly.

4) Answering procedural questions.

2. Panel Monitors must not require reviewers on their panels to reach 

consensus regarding comments and scores. Instead, they ensure that all 

panel members have the opportunity to discuss the extent to which 

applications responded to the competition’s selection criteria and that 

discrepancies in comments or scores among reviewers are not the result of a 

factual misunderstanding (e.g., one reviewer stated that an application did not 

include a key element but another reviewer found that element and cited a 

specific page). A natural evolution to consensus resulting from this panel 

practice is acceptable.
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B. Procedures – Reserved

C. Guidance

1. Program offices may also establish a Panel Chair in the review process. A 

Panel Chair is typically a reviewer who has previous experience with ED’s 

application review process, has a general knowledge of the program, and is 

considered an expert on the panel to lead the discussions among peer 

reviewers. Program offices may also rotate the Panel Chair position among 

peer reviewers when lead reviewers are assigned to specific applications for 

the purpose of leading the panel’s discussions about their assigned 

applications.

D. Other Pertinent Information – Reserved

3.5.10 Orientation of Peer Reviewers

A. Policy

1. The Competition Manager ensures that the review process adheres to the 

approved ATRP and all other governing procedures (i.e., in this Handbook, 

program office’s SOPs for conducting peer reviews) by convening orientations 

for peer reviewers prior to beginning the review process.

B. Procedures

1. Program offices peer reviewer orientation includes information about:

a. Their responsibilities as peer reviewers;

b. The purpose of the program;

c. The purpose of the review; and

d. The roles and responsibilities of those involved in the review.

2. Before individuals begin to review applications, the Competition Manager, 

during the reviewer orientation:

a. Instructs reviewers on confidentiality (see the section Confidentiality of the 

Review Process);

b. Instructs reviewers that they independently review and score all 

applications assigned to them and evaluate each application based solely 

on the selection criteria and priorities, if any, published in the Federal 

Register; 
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c. Provides each reviewer with a list of all applications to be reviewed, if they 

have not already done so, to identify potential conflicts of interest before 

the application reviewer packages are given out;

d. Instructs reviewers that they immediately notify the appropriate program 

office if they identify a possible conflict of interest at any time in the review 

process; 

e. Provides each reviewer an application reviewer package, if they have not 

already done so (see the section Packages for Peer Reviewers);

f. Ensures that each reviewer understands the conflict of interest policy and 

signs the appropriate conflict of interest form;

g. Confirms that each reviewer who is receiving compensation under a 

purchase order does not appear in the Excluded Parties List System 

(EPLS) database available at SAM.gov. ED staff makes final 

determinations regarding the reviewer roster, including confirming that no 

selected reviewers appear on the EPLS database, even if a contractor is 

primarily responsible for checking reviewer names against the EPLS 

database;

h. Informs reviewers that they must complete a scoring form for each 

application reviewed;

i. Explains to reviewers that scores must be based on published criteria and 

that scores can be changed after panel discussions, if necessary, but that 

changes are not required;

j. Instruct reviewers to document scores with comments that justify the 

assigned scores, and provide constructive comments that provide 

meaningful information to the applicant, including suggestions for 

improvement where it would be helpful;

k. Explains the approach used in the competition to evaluate applications 

(see the section Scoring Rubrics);

l. Explains whether reviewers are authorized to evaluate the extent to which 

an application addresses a competitive preference priority.

1) Peer reviewers review competitive preference points when assigning 

points is dependent upon subjective judgment (i.e., interpretation 

based on expertise) on the part of a content expert peer reviewer.

2) However, when assigning points is dependent upon objective judgment 

(i.e., lacking subjectivity and instead based on fact), it is carried-out by 

the program office.
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3) The decision regarding who reviews and scores a competitive 

preference priority was already made in consultation with the program 

attorney before the review process, and most likely occurred in 

planning the competition.

m. Informs reviewers that, for questions or issues that must be elevated for 

resolution beyond the panel monitor, it is the program official who has final 

authority to address any questions or resolve any issues that might arise 

concerning ED rules and practices;

n. Instructs reviewers to complete an evaluation of the process at its 

conclusion;

o. Instructs reviewers to provide required information necessary for 

reimbursement for their services, if applicable; and

p. Instructs reviewers that they complete all reviews by the end of the review 

process to receive payment or reimbursement.

C. Guidance

1. For time-saving purposes, a best practice is to have more reviewers than 

needed participate in the reviewer orientation. In the event a reviewer needs 

to be replaced, then an alternate reviewer is already prepared.

D. Other Pertinent Information

1. Program staff may use the computer-based training course, Introduction to 

Being an Effective Peer Reviewer for training new and experienced reviewers 

about the peer reviews process.

3.5.11 Confidentiality of the Review Process

A. Policy

1. The Competition Manager ensures the confidentiality and integrity of the 

review process.

B. Procedures

1. Before the review of any applications, the Competition Manager instructs the 

reviewers and provides in writing that:

a. They must not discuss or share the contents of an application with anyone 

outside of their panel during the review process or after the review 

process has been completed;
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b. They must ensure no other person has access to the grant applications;

c. For reviews conducted using e-Reader, they must not allow others to 

access e-Reader or their password or identification number, study their 

computer screen while entering scores and comments, or allow others to 

enter their comments or scores unless the reviewer is an individual with a 

disability who may need the assistive services of other persons during the 

peer review process;

d. At the end of the review process, they must destroy any notes that were 

taken during the review of any/all applications they were assigned;

e. At the end of the review process, they must destroy any copied 

documents from the application;

f. At the end of the review process, they must delete all electronic files that 

were created in conjunction with the review process; and

g. At the end of the review process, they must destroy mailed applications or 

return them to ED (per the Competition Manager’s instructions) 

immediately after completing the review.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

3.5.12 Replacement of Reviewers During the Review

A. Policy

1. If panels of reviewers are used to review the applications, each panel consists 

of the same number of people.

2. The reviewers assigned to a panel participate in that panel throughout the 

review process unless the Competition Manager finds it necessary to replace 

a reviewer after the start of the review process.

3. The Competition Manager only replaces reviewers for justifiable reasons such 

as:

a. Conflict of interest issues;

b. The reviewer is not performing to agreed expectations; or

c. The reviewer has an emergency that prohibits him/her from completing the 

review process.
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4. The Competition Manager will not replace a reviewer because the program 

office disagrees with the reviewer’s documented scores or comments or 

because there is a disparity in the scores of this reviewer and those of other 

reviewers unless the disparate scores are not well supported.

5. The Competition Manager ensures that the replacement reviewer meets the 

same standard for approval as the original reviewer and is provided 

orientation, training, and consultation comparable to that provided to other 

reviewers.

B. Procedures

1. If it becomes necessary to replace a reviewer after the competition has 

begun, for any of the reasons addressed in the policy section, the program 

official develops the following documentation and will place it in the 

competition file:

a. An explanation of the reason(s) for the replacement;

b. The process used to assign applications to the replacement reviewer;

c. A description of the efforts taken to resolve any problems prior to the 

replacement, if applicable;

d. The number of applications assigned to the panel;

e. The number of applications read by the original reviewer with the 

PR/Award number of each;

f. An explanation of the steps taken to ensure that both the original and 

replacement reviewers have reviewed sufficient applications within the 

panel to ensure fair and equitable treatment of applications, considering 

that determining a fair and equitable treatment of applications, if an 

alternate reviewer is used during the competition, will be on a case-bycase basis because the reason for removing the original reviewer should 

be considered;

g. The number of applications to be reviewed by the replacement reviewer; 

and

h. The original reviewer’s completed application review forms, if any.

C. Guidance

1. Every attempt is made to maintain the diversity of the reviewer panels, 

considering the qualifications, background, and experience of the reviewer(s) 

being replaced.
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D. Other Pertinent Information – Reserved

3.6. Conflict of Interest

3.6.1 Reviewing Reviewer Information for Conflicts of Interest

A. Policy

1. Program offices make reasonable efforts to recruit reviewers who have 

expertise in areas pertinent to each of their discretionary grant programs.

2. Individuals interested in becoming a reviewer complete an application or 

submit a resume, or curriculum vitae, or other comparable information to the 

program that administers the competition.

3. For reviews that are conducted in e-Reader, reviewers first register and 

complete a reviewer profile in the grants management system in order to 

review applications in e-Reader.

4. Program offices ensure that reviewers have the necessary qualifications to 

review applications that will be submitted in upcoming competitions.

5. Program offices ensure that reviewers do not have any actual or apparent 

conflicts of interest in the outcome of upcoming competitions, or that there are 

no other reasons for which the public would question their objectivity to serve 

as a reviewer.

6. To ensure a fair and competitive application review process, program offices 

identify potential peer reviewer conflicts of interest, or other factors that might 

affect objectivity, to the extent possible, before approving a final peer reviewer 

roster (i.e., a roster of reviewers that actually conduct the review after all the 

conflicts have been checked and addressed, if necessary) and prior to the 

start of a competition’s application review process.

a. Peer reviewers, who are employees of a Federal government agency 

other than ED, are not considered ED employees.

7. Program offices work closely with OGC’s Ethics Division in determining 

whether there are possible financial interests or other reasons for which the 

public would question the objectivity of a potential reviewer in a competition.

B. Procedures

1. Program offices determine whether potential reviewers have the necessary 

qualifications to review applications for upcoming competitions by reviewing 

resumes, curriculum vitae, or other pertinent and comparable information.
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2. Program offices review resumes, curriculum vitae, or other pertinent and 

comparable information to determine if potential peer reviewers have any 

conflicts of interest (direct or indirect) in the outcome of upcoming 

competitions, or if there are other reasons for which the public would question 

their objectivity to serve as a reviewer.

3. To the extent possible, before selecting reviewers for a competition, program 

offices compare the list of all applicants in the competition to the list of 

potential reviewers, and their employers, to determine if the employer of any 

potential reviewer has submitted an application in that competition.

4. To the extent possible, after selecting reviewers, but before the start of the 

review, the program office provides each reviewer with a list of the 

competition applications assigned to that reviewer for review so that the 

reviewer may identify any conflicts of interest, or any other circumstances that 

would impair his or her ability to impartially review any application in the 

competition.

C. Guidance

1. In addition to reviewing resumes and/or curricula vitae, program offices may 

conduct Internet or other searches, and may use specific questionnaires, 

surveys, or interviews of potential reviewers to gather more information 

relevant to the review. In conducting this review, program offices may wish to 

use functionalities of the grants management system that can search 

reviewer profiles for key terms. For example, program offices may search a

reviewer’s profile for resume or curriculum vitae information related to 

“significant connections to teaching methodologies,” “significant identification 

with pedagogical viewpoints,” “significant connections to related matters,” or 

”philosophical viewpoints that may be involved in the competition” (see the 

section Process for Addressing Other Factors That Might Affect Objectivity). 

Assuming reviewers have entered related information in their profiles, 

program offices would be able to pinpoint applicable references through 

queries in the “Inquire on Reviewers” screens of the “Maintain Pool of 

Reviewers” module using the Smart Search function in e-Reader.

2. Program offices should ask a series of questions concerning possible 

conflicts of interest, and other factors that might affect objectivity, when an 

individual is contacted about serving as a reviewer. A list of sample questions 

that may be used for this purpose is available in the document titled, 

Questions for Application Reviewers on Conflict of Interest and Other Factors 

That Might Affect Objectivity, which is available at the following link: 

Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process. 
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3. It may also be appropriate to ask questions other than those provided in the 

Questions for Application Reviewers on Conflict of Interest and Other Factors 

That Might Affect Objectivity document. Program offices should work closely 

with OGC’s Ethics Division to develop their own questions to address 

possible conflicts of interest, or other factors that might affect objectivity, 

related to a specific competition. Additionally, the Ethics Division is available 

to work with program offices to develop effective strategies for identifying 

possible disqualifying conflicts of interest prior to the start of a competition 

cycle. 

D. Other Pertinent Information

1. For information regarding registering and completing a reviewer profile in the

grants management system, individuals can access the online training topic 

for Reviewers (Field Readers)” from the homepage, and/or contact the 

external Hotline number at 1-888-336-8930 or at 

obssed@servicenowservices.com. 

2. Program offices, regarding queries in the “Inquire on Reviewers” screens of 

the “Maintain Pool of Reviewers” using the Smart Search function in eReader, may contact the internal Hotline at (202) 401-6238 or at

obssed@servicenowservices.com

3. Information about OGC’s Ethics Division, including contact information, can 

be found at: Ethics Division. 

3.6.2 Reviewers with Conflicts of Interest

A. Policy

1. A reviewer who is not a Federal employee will be considered to have a 

conflict of interest when the reviewer, or certain individuals and entities with 

which the reviewer has a relationship, has a financial interest in the outcome 

of the competition for which he or she is serving as a reviewer.

2. A reviewer has a direct conflict of interest and will be dismissed from serving 

as a reviewer for the competition if:

a. The reviewer has agreed to serve as an employee, advisor, contractor or 

consultant on a project for which funding is being sought in an application 

under review, or has been offered the opportunity to do so and has not yet 

accepted or declined the offer, based on whether a grant is awarded;

b. The reviewer’s personal financial interests will be affected by the outcome 

of the competition; or
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c. The reviewer helped prepare an application in the competition, even if the 

reviewer has no financial interest in the outcome of that application;

3. A reviewer has an indirect conflict of interest if the reviewer has a relationship 

with an entity or individual that has a financial interest in the outcome of the 

competition. An indirect conflict of interest is assessed on a case-by-case 

basis. Under these circumstances, a reviewer may or may not be allowed to 

continue to serve as a reviewer for the competition.

Examples of such a relationship, include, but are not limited to, the following:

a. The reviewer’s spouse, his or her child, a member of his or her household, 

or any relative with whom he or she has a close relationship;

b. Any employer the reviewer has served within the last 12 months, a 

business partner, an organization for which the reviewer has served as an 

officer, director, employee, consultant, advisor, contractor, or trustee 

within the last 12 months, or an organization for which the reviewer serves 

as an active volunteer or participant;

c. Any person or organization with whom the reviewer is seeking, or has an 

arrangement concerning, future employment;

d. Any professional associate – including, but not limited to, any colleague, 

scientific mentor, or student – with whom the reviewer is currently 

conducting research or other professional activities or with whom he or 

she has conducted such activities within the last 12 months; or

e. Any individual with whom the reviewer has, or has had, a personal 

relationship where the nature, duration, or recentness of that relationship 

would impair his or her ability to impartially review any application in the 

competition.

4. Notwithstanding the scenarios described above for identifying either a direct 

or an indirect conflict of interest, before and during the review process, the 

program official and reviewers also identify any other circumstances that 

might cause a reasonable person to question a reviewer’s impartiality in 

serving as a reviewer on a particular competition, see the section Reviewing 

Reviewer Information for Conflicts of Interests. 

B. Procedures

1. All reviewers complete the appropriate Agreement for Grant Application 

Reviewers forms Department of Education Agreement for Grant Application 

Reviewers Who Receive Compensation, or Department of Education 

Agreement for Grant Application Reviewers Who Serve Without 
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Compensation, which are available at the following link: Documents and 

Forms Referenced in the Handbook for the Discretionary Grant Process. 

2. If a reviewer has a conflict of interest with any application, that reviewer shall 

not participate as a reviewer in the competition unless the exemption 

described for large competitions in the “Conflict of Interest Exemption for 

Large Competitions” section applies or, if appropriate, the reviewer has been 

granted a waiver pursuant to the “Individual Conflict of Interest Waivers” 

section.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

3.6.3 Conflicts Related to Applications from a Consortium of Entities

A. Policy

1. A reviewer is considered to have a conflict of interest with applications 

submitted by consortiums when the reviewer has a relationship with a 

member of a consortium, or with a partner in an application, that has a 

financial interest in the outcome of the competition for which the reviewer is 

serving as a reviewer.

B. Procedures

1. Program offices develop and implement strategies for identifying and avoiding 

conflicts of interest that arise when a reviewer has a relationship with a 

member of a consortium, or with a partner in an application, that may not be 

immediately apparent from reviewing an application’s title page.

C. Guidance

1. Some discretionary grant programs require applicants to include several 

different types of entities in their proposals. When an application is received 

from a consortium, or other cooperative arrangement of several entities, it is 

not always easy to tell from simply looking at the list of applicants what 

potential conflicts of interest exist. Program offices should consult with OGC’s 

Ethics Division, to develop effective strategies for identifying disqualifying 

conflicts of interest in applications received from a consortium of entities.

D. Other Pertinent Information – Reserved
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3.6.4 Conflicts Related to State University Systems and Multiple 

Campuses

A. Policy

1. An application submitted by a campus that is a member of a multi-campus 

system is generally NOT considered an application from the entire system of 

institutions. Therefore, reviewers from most multi-campus institutions may 

serve as reviewers in a competition in which another campus of the system 

has applied. Examples of multi-campus systems that consider campuses in 

their system as individual entities are listed in the Multi-Campus Higher 

Education Systems document available at the following link: Documents and 

Forms Referenced in the Handbook for the Discretionary Grant Process. 

B. Procedures – Reserved

C. Guidance

1. For institutions not included in the Multi-Campus Higher Education Systems 

document, program offices should consult with OGC’s Ethics Division on a 

case- by-case basis to determine whether a specific campus of a multicampus system is independent. Factors that can be considered when making 

this determination include whether the campus has a different geographical 

location, an independent governing body, or a separate funding source.

D. Other Pertinent Information - Reserved

3.6.5 Conflict of Interest Exemption for Large Competitions

A. Policy

1. With respect to grant competitions with a large number of applications, ED 

has determined that some individuals may participate as reviewers, 

notwithstanding certain conflicts of interest. An individual for whom a conflict 

of interest has been identified may serve as a reviewer when the following 

conditions are met:

a. The individual does not have a personal financial interest in any proposed 

project (See Section 3.6.2 Reviewers with Conflicts of Interest);

b. The individual did not prepare or help prepare an application under review 

in the competition, even if he or she has no financial interest in the funding 

of that application;

c. The individual will not serve as an employee, advisor, contractor, or 

consultant, or otherwise provide services, on any proposed project even if 

his or her compensation is not contingent on a grant award;
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d. The competition has received and will review at least 80 applications; and

e. The review will be comprised of at least eight panels of three or more 

reviewers.

2. It is not necessary for ED to issue a written waiver or exemption for large 

competitions when all these conditions have been met.

B. Procedures

1. If an individual with a conflict of interest is permitted to serve as a reviewer 

because the conditions listed above are met, program officials apply the 

following restrictions. The reviewer will not:

a. Be assigned to review any application submitted by his or her employer, 

nor anyone for whom he or she serves as a consultant, advisor, or 

contractor;

b. Serve on the panel assigned to review the application giving rise to the 

conflict of interest;

c. Attend any panel meetings during which the conflicting application is 

discussed; or

d. Serve as a Panel Chairperson.

2. Prior to reviewing any applications, reviewers will examine the assigned 

applications. If a reviewer identifies any of the applications as having been 

submitted by his or her employer, or by any organization for which he or she 

serves as a consultant, advisor, or contractor, the program official will assign 

the application to another panel. If a reviewer identifies any other real or 

apparent conflict of interest—for instance, that the reviewer’s sibling is named 

as the project director for implementation of the proposed program in another 

state—the reviewer notifies the program official immediately.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

3.6.6 Individual Conflict of Interest Waivers

A. Policy

1. When needed and appropriate, a Principal Officer must request an individual 

waiver for a peer reviewer when the exemption for large competitions does 

not apply.
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2. An individual waiver is issued only when a determination that no other 

individual with comparable expertise who is not subject to a conflict-of-interest 

disqualification is available to serve as peer reviewer, and the need for the 

individual’s services outweighs the potential for a conflict of interest raised by 

the identified conflicting interest.

3. The Principal Officer and the ED contracting officer will issue individual 

waivers, with concurrence of the OGC Ethics Division. 

4. A waiver will almost never be approved when the conflict of interest arises 

from the personal financial interest of the reviewer. A personal financial 

interest includes, but is not limited to, situations in which: 1) a reviewer or 

reviewer’s spouse would receive or lose compensation depending on whether 

an application in the competition is funded; or 2) the reviewer or reviewer’s 

spouse has agreed to serve as a paid consultant, advisor, or contractor to an 

applicant if its application is funded.

5. Waivers are approved on a case-by-case basis and are not granted 

automatically.

B. Procedures

1. To request and obtain a waiver, Principal Officers provide a memorandum to 

the ED contracting officer and OGC’s Ethics Division using the template 

Request for Approval of a Conflict of Interest Waivers, which is available at 

the following link: Documents and Forms Referenced in the Handbook for the 

Discretionary Grant Process. 

2. Documentation concerning a reviewer’s conflict of interest and a copy of any 

waiver is included in the grant program competition file see the Department of 

Education Certification for a Grant Application Reviewer with a Conflict of 

Interest form available at the following link: Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. 

C. Guidance

1. To the extent possible, individual waivers should be requested and issued 

prior to the start of a review. However, individual waivers will be considered 

after the start of the review when conflicts of interest are identified through the 

review process. Nevertheless, a reviewer will not be permitted to begin the 

review until the individual waiver has been issued.

D. Other Pertinent Information – Reserved
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3.6.7 Waiver Restrictions

A. Policy

1. A reviewer who has been granted a waiver, or who is reviewing applications 

under the exemptions for large competitions, does not review the application 

with which the reviewer has a conflict of interest.

a. For instance, if a reviewer employed by the University of Arkansas is 

granted a waiver to review applications in a competition in which the 

University of Arkansas is an applicant, that reviewer does not review the 

University of Arkansas’s application.

2. A reviewer who has a conflict of interest with an application does not attend 

any panel meetings in which the application is discussed or have access to 

the application or any information concerning its review.

3. Reviewers who have a conflict of interest with an application being reviewed 

by the panel are required to serve on a different review panel, unless the 

competition manager moves the application in question to a different panel.

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

3.6.8 Reviewers Who Are Federal Employees

A. Policy

1. Rules governing conflicts of interest for Federal employees are found in 18 

U.S.C.§ 208 – a Federal criminal statute – and Subpart E of the Standards of 

Ethical Conduct for Employees of the Executive Branch at 5 C.F.R. § 2635.

B. Procedures

1. Federal employees from other agencies serving as peer reviewers consult 

with their agency’s ethics office to discuss any potential conflict of interest 

associated with participation and then to obtain approval to participate as 

peer reviewers for the competition.

2. At ED, employees contact OGC’s Ethics Division to determine if there is the 

possibility of, or if there exists, a conflict of interest before agreeing to serve 

as reviewers, whether the competition is internal to ED or the competition is 

hosted by another Federal agency.
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C. Guidance – Reserved

D. Other Pertinent Information

1. Governing conflicts of interest rules for Federal employees are found in 18 

U.S.C.§ 208 – a Federal criminal statute – and subpart E of the Standards of 

Ethical Conduct for Federal Employees at 5 C.F.R. § 2635).

3.6.9 Process for Addressing Other Factors That Might Affect 

Objectivity

A. Policy

1. Programs ensure that other reasons for which the public would question the 

objectivity of a potential reviewer in the competition do not exist.

2. Factors that are to be considered in determining whether there are other 

reasons for which the public would question the reviewer’s objectivity to serve 

as a reviewer in the competition include whether the reviewer has “significant 

connections to teaching methodologies” that may be involved in the 

competition, “significant identification with pedagogical viewpoints”, 

“significant connections to related matters,” or “philosophical viewpoints that 

may be involved in the competition.”

3. In assessing other factors that might affect objectivity, programs consider 

whether the particular competition itself presents issues or connections to any 

specific teaching methodology, or significant identification with pedagogical or 

philosophical viewpoints that may be involved in the competition such that a 

peer reviewer may have views that would create a reason to question the 

objectivity of the individual to serve as a reviewer.

4. Programs include a process for addressing other factors that might affect 

objectivity in the ATRP.

5. The large group exemption set out in the Conflict of Interest Exemption for 

Large Competitions section and the individual waiver process set out in the 

Individual Conflict of Interest Waivers section are not subject to the policy, 

guidance, and procedures addressed in this section.

B. Procedures

1. Question 7 of the questionnaire titled, Questions for Application Reviewers on 

Conflict of Interest and Other Factors That Might Affect Objectivity may be 

asked of potential reviewers to determine if they have significant connections 

to teaching methodologies or significant identification with pedagogical 

viewpoints that are pertinent to the grant competition to be peer reviewed or 

significant connections to related matters or philosophical viewpoints. In 
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addition, language concerning other factors that might affect objectivity is 

included in the conflict of interest certifications in the agreements for peer 

reviewers that serve with and without compensation.

2. If other factors, such as a teaching methodology, pedagogical viewpoint, or 

philosophical viewpoint, are not involved in the competition in a way that 

would cause a reasonable person to question the objectivity of a peer 

reviewer associated with or connected to one particular methodology or 

viewpoint, programs are to state this fact within the ATRP. However, if any of 

these factors are involved in the competition, programs are to describe, in the 

ATRP for each competition they run, the steps they will take to address the 

factors that might affect objectivity. These steps could include:

a. Describing a process for recruiting peer reviewers that seeks a broad 

range of experiences and perspectives;

b. Describing a process for reviewing the answer to question 7 of the 

questionnaire titled Questions for Application Reviewers on Conflict of 

Interest and Other Factors That Might Affect Objectivity and, as 

determined appropriate by the Competition Manager—on the basis of 

such factors as the particular circumstances of the competition (e.g., 

whether it is focused on subjects that are highly controversial or involves 

competing schools of thoughts) or the nature of the answers provided by 

potential peer reviewers—reviewing any writings or publications provided 

in response to this question;

c. Incorporating the language on other factors that might affect objectivity in 

the conflict of interest certification that is part of the agreements for peer 

reviewers that serve with and without compensation;

d. Describing a process to balance the types of experience and perspectives 

that are present on each peer review panel in a competition;

e. Describing a process that ensures panel discussion in cases where there 

are significant discrepancies in scores between peer reviewers to ensure, 

among other things, that applications are being rated on the basis of the 

selection criteria rather than on some other factor, such as a peer 

reviewer’s connection with a particular philosophy or school of thought; 

and,

f. Describing a process for monitoring peer reviewer comments on technical 

review forms to ascertain whether the scores given are justified on the 

basis of the content of the application and the selection criteria.

3. In instances in which there is substantial reason to believe that there exists 

other factors that may question the objectivity of an individual to serve as a 

reviewer in a competition, and programs wish to not use the individual as a 
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reviewer, programs consult with the program attorney and with OGC’s Ethics 

Division about not using the individual as a reviewer in the competition.

4. When program offices deem that it is appropriate to use individuals having the 

types of conflict factors described in this section as reviewers, they seek 

exceptions from their program attorney and OGC’s Ethics Division that will 

allow them to mitigate the issue and modify the role of the individual, or that 

will allow them to limit the applications reviewed by the individual.

5. For assistance in assessing whether other factors that might affect objectivity 

exist, programs work closely with the program attorney and Ethics Division to 

determine if there are other reasons for which the public would question the 

objectivity of a potential reviewer in the competition.

C. Guidance

1. In considering “significant connections to teaching methodologies,” programs 

should examine whether there are specific teaching methods associated with 

the subject of the competition (e.g., how a subject area is taught or whether 

there are particular subject matters, techniques, or methods related to the 

teaching of the subject to the students) that if a reviewer were significantly 

connected to one or more of these methodologies, the public would have a 

substantial reason to question his/her objectivity to serve as a reviewer in the 

competitions.

2. In considering “significant identification with pedagogical viewpoints,” 

programs should examine whether there are specific theories or philosophies 

associated with the subject of the competition that if a reviewer were 

significantly connected to one or more of these theories or philosophies, the 

public would have a substantial reason to question his/her objectivity to serve 

as a reviewer in the competitions.

3. In determining when there are “significant connections” or “significant 

identification with philosophical viewpoints” that may be involved in the 

competition, ED considers such factors as the nature, duration, extent, and 

the recentness of the connection or identification.

4. When including a process for addressing other factors that might affect 

objectivity in the ATRP, the following statement may be included when a 

teaching methodology, pedagogical viewpoint, or philosophical viewpoint is 

not involved in the competition in a way that would cause a reasonable 

person to question the objectivity of a peer reviewer associated with or 

connected to one particular methodology or viewpoint:

“Specific teaching methodologies, pedagogical viewpoints, and/or 

philosophical viewpoints are not involved in this competition in a way that 
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would cause a reasonable person to question the objectivity of a peer 

reviewer associated with or connected to that methodology or viewpoint.” 

5. When including a process for addressing other factors that might affect 

objectivity in the ATRP, the following statement may be included to describe 

how responses to question 7 of the questionnaires titled, “Questions for 

Application Reviewers on Conflict of Interest and Other Factors That Might 

Affect Objectivity,” and any writings or publications provided in response to 

this question, will be reviewed:

a. When reviewers disclose that they have written, published, or otherwise 

commented on or been connected to any specific teaching methodology, 

or significantly identified with any pedagogical or philosophical viewpoints 

associated with a competition, and further explain that their connection or 

significant identification may cause someone to question their objectivity, 

program offices will: 1) review the responses to question 7 of the 

questionnaire titled, Questions for Application Reviewers on Conflict of 

Interest and Other Factors That Might Affect Objectivity; 2) request and 

review applicable copies of written and/or published works as deemed 

appropriate by program office; and 3) make a determination regarding the 

reviewers’ objectivity.

b. Program offices will consult with OGC’s Ethics Division when assistance is 

needed in determining if a significant connection or significant 

identification exists. All related documentation, decisions, and final course 

of action will be filed in the official competition file.

D. Other Pertinent Information

1. Program offices may access the questionnaires, Questions for Application 

Reviewers on Conflict of Interest and Other Factors That Might Affect 

Objectivity and the peer reviewer agreements at the following link: Documents 

and Forms Referenced in the Handbook for the Discretionary Grant Process. 

3.7 Peer Review Scoring and Quality Control

3.7.1 Limiting the Standardization of Peer Reviewers’ Scores

A. Policy

1. Program offices select high-quality grant applications for funding in a fair and 

transparent manner based on peer review scoring that is representative of 

detailed assessments that measure the extent to which selection criteria are 

comprehensively addressed by applicants.
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B. Procedures

1. To select high-quality projects in a fair and transparent manner, program 

offices conduct an application peer review process where reviewers use their 

professional judgment to consistently review applications against selection 

criteria and consistently award point values to applications across programs.

2. Peer review scores are only standardized in exceptional circumstances, and 

only after consultation with the program attorney. If, after this process, 

program offices decide to standardize16 peer review scores after the panel 

review has concluded, they document this determination in the competition 

file, including a rationale for the standardization, the process for doing so, and 

the effect, if any, the standardization had on the rank order of applications.

C. Guidance

1. Program offices should hold a discussion with their program attorney in the 

competitions planning stage to inquire about using standardization if, based 

on the programs historical data it’s been determined when to use raw scores 

versus adjusted scores, and the method of standardization is a useful and 

beneficial tool for the program. Program offices should also know that there 

are valid circumstances in which standardization should not be used.

2. Program offices should regularly consider ways to improve the consistency 

and quality of peer reviewer scoring.

D. Other Pertinent Information – Reserved

3.7.2 Ensuring the Consistency and Quality of Peer Reviewer Scoring

A. Policy

1. Program offices ensure the consistency and quality of peer reviewer scoring 

by focusing on recruiting reviewers who have background and expertise in the 

subject area of the competition, and by thoroughly and uniformly orientating 

or training them on expectations about scoring methods and practices (see 

the sections Recruiting Reviewers for the Reviewer Database, Selecting 

Reviewers for a Reviewer Roster, and the Orientation of Peer Reviewers).

B. Procedures

1. To ensure the consistency and quality of peer reviewer scoring, program 

offices develop thorough and uniform peer reviewer orientations or trainings 

16 Standardization is a statistical procedure, valid if certain assumptions are met, to correct the effect of 

any possible “bias” introduced by differing reviewer approaches to assigning raw scores. Raw score is the 

average of all reviewer scores.
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that cover the substantive programmatic elements of a particular competition, 

such as the authorized activities, funding priorities, and selection criteria as 

well as ED guidelines and expectations about scoring methods and practices.

2. Program offices provide this training to ED staff or contractors who have been 

recruited to serve as Panel Monitors.

C. Guidance

1. Program offices should use available peer reviewer information in the grants 

management system e-Reader to identify potential reviewers and to get an 

objective assessment of peer reviewers’ previous performance, especially as 

it relates to their scoring competence and reliability. Completed evaluations of 

peer reviewer and review panel performances are available in e-Reader, 

when Panel Monitors have entered those evaluations in the e-Reader system.

2. When considering peer reviewers for participation in their panels, Competition 

Managers might also benefit from consulting with employees in ED or other 

agencies, who have previously worked with particular peer reviewers, to 

assess the individuals’ skills and competence in scoring applications reliably.

3. Elements that program offices should consider, including in their peer 

reviewer orientations and trainings, that will improve the reliability and quality 

of scores are provided below:

a. Common point of departure in scoring applications -

1) One of the key elements of consistency in scoring involves establishing 

a common point of departure for peer reviewers’ reviews, in order to 

ensure that all applications start on an equal footing. Program offices 

have discretion about the starting point for assigning the number of 

points to the review criteria for the applications.

2) Program offices, for example, might choose to conduct a scoring 

process where the application is presumed to begin with zero points. In 

this method, peer reviewers would be trained to proceed by adding 

points for the applicant’s response to each criterion, to the extent that 

the quality of information provided in the application continues to justify 

points.

b) The burden of proof would rest with the applicant to demonstrate 

that it has provided clear evidence that it has effectively addressed 

the selection criterion to justify the points that the peer reviewer 

assigns.

3) Program offices might use a different starting point for scoring. For 

example, another approach could be to presume that all applications 
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start out with a perfect score, and readers are asked to deduct points 

for deficiencies they see in the applications.

4) Program offices might take any of several different approaches. 

Whatever the method used for a competition, program offices should 

make sure that reviewers receive training on the scoring approach they 

all must use to evaluate applications and that they present comments 

that support the number of points they assign for a criterion or priority.

b. Peer reviewer comments and points -

1) The peer reviewer training and orientation should also emphasize the 

importance of peer reviewer comments supporting the points a peer 

reviewer gives an application under each selection criterion.

2) Requiring peer reviewers to justify their point allocations with 

explanatory comments helps Panel Monitors (and the applicant and 

public) gain insight into and confidence in the points awarded by the 

peer reviewers.

3) High scores should be supported by detailed statements about 

associated strengths in the application, just as low scores should have 

strong supporting comments about associated weaknesses.

4) Training should alert peer reviewers to look for comprehensive 

responses by an applicant to a program’s selection criteria and 

priorities, and to consider salient and responsive information 

throughout the entire application. Important details that are overlooked 

or insignificant items that are given too much weight by a single peer 

reviewer could lead to discrepancies that might skew scores and 

undermine the quality ranking of applications.

5) Training and orientation of peer reviewers should convey to them the 

importance of their efforts to make their scores and comments work 

together to present the clearest possible picture of a peer reviewer’s 

assessment of an application and the extent to which the application 

has addressed program selection criteria and priorities.

c. Peer reviewer calibration -

1) Peer reviewer calibration is a procedure for training peer reviewers that 

can improve inter-reviewer reliability. The training can involve having 

peer reviewers read and score model or representative applications, 

from previously completed competitions, of quality levels already 

known to the Competition Manager.
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This activity will allow peer reviewers to get a sense of the probable 

range of quality among the types of applications that they will be 

reviewing and help them score applications effectively, to reflect those 

relative levels of quality.

These models might be actual applications from the program’s 

previous competitions (with personally identifiable information or other 

proprietary data removed), or they could be sample applications 

created by the program for this type of exercise. In either case, their 

quality levels or previous scoring would not be disclosed to the peer 

reviewers before the exercise.

The model applications should be enough (e.g., a suggested minimum 

of three) to represent a variety from very low to very high quality, so 

that peer reviewers can understand where, along the range of possible 

point values, applications of different levels in the competition would 

fall.

In such an exercise, the peer reviewers would rate the model 

applications, after which the competition manager would discuss with 

the peer reviewers how their scores compared with the applications’ 

actual historical scores. This can help peer reviewers learn how to 

score applications better and help Competition Managers to assess 

peer reviewers’ understanding of the relationship between the 

selection criteria and the numerical points that would normally be 

assigned to specific levels of quality, often described with such terms 

as “fair,” “good,” “very good,” “excellent,” etc.

2) Competition Managers could introduce additional training for any 

specific peer reviewer(s) who appear to rate the model applications 

consistently higher or lower than the norm, in order to reinforce the 

ED’s process for obtaining accurate scores, with a view to improving 

the scores’ subsequent reliability.

In addition to working with any individual reviewer, Competition 

Managers might find it useful to facilitate a discussion with all the 

reviewers to foster a better group understanding of assigning points for 

the various review criteria.

This method of orientation and calibration requires time and effort. Its 

effectiveness as a calibration tool increases as the number of 

applications and peer reviewers increase. Therefore, programs can 

consider the feasibility or advisability for competitions with small 

numbers of applications and peer reviewers.
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3) It is also recommended that programs retain these “test” or “pilot” 

scores from the calibration exercises, since they might be useful for 

post- competition comparison, especially in assessing any remaining 

peer reviewer scoring bias that might still be evident.

D. Other Pertinent Information – Reserved

3.7.3 Scoring Rubrics

A. Policy

1. There are two types of scoring rubrics: non-advisory (binding) and advisory 

(non- binding).

2. When program offices develop non-advisory scoring rubrics (i.e., descriptions 

for how to assign point values based on quality of the application) that must 

be used by the peer reviewers to score applications, they establish the rubrics 

through notice-and-comment rulemaking and publish them in the Federal 

Register, unless an exception applies.17

3. Rubrics that are merely advisory (i.e., non-binding) are not required to go 

through the rulemaking process. However, some rubrics, even though 

advisory, may be specific enough that they must go through the rulemaking 

process and be published in the Federal Register, unless an exception 

applies.

4. The distinction between the two types of scoring rubrics is whether the rubrics 

create specific cutoffs and criteria or whether they are advisory guides for 

consistent evaluation of applications. A non-advisory rubric would be a “rule” 

and require rulemaking unless an exception applies. Advisory rubrics may not 

require rulemaking, but that would be determined on a case-by-case analysis.

B. Procedures

1. Program offices ensure that all scoring rubrics, whether advisory or nonadvisory, are reviewed by the program attorney before they are placed in 

application packages to ensure that rulemaking is not necessary.

2. Program offices include scoring rubrics (advisory and non-advisory) in their 

application packages.

17 One exception to the notice-and-comment rulemaking requirement might involve a program that is 

authorized by new or substantially revised legislative language. Under this circumstance, there would be 

an exception to the notice-and-comment process because this would be the first competition under such 

a program. See 20 U.S.C.§1232(d)(1).
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C. Guidance

1. To promote peer reviewer scoring consistency and reliability, and to minimize 

the subjectivity of scoring judgments made during application reviews, 

program offices may develop standard, detailed scoring rubrics for grant 

competition selection criteria.

2. Program offices that plan to use non-advisory scoring rubrics for their 

application reviews consult with their program attorney during the planning 

process for the competition to help ensure the appropriateness of the 

proposed scoring rubrics to the grant competitions and to ensure that all 

rulemaking requirements are met.

3. Advisory scoring rubrics that do not require notice-and-comment rulemaking 

and publication in the Federal Register are included in the application 

package for a competition. This is because the rubric information could be 

beneficial to potential applicants or the general public in understanding more 

fully how applications will be evaluated.

4. Program offices should develop scoring rubrics that provide peer reviewers 

with specific scoring guidance that helps define the relationship between a 

score and the quality of an application with respect to each selection criterion.

5. There are three general approaches to evaluating applications:

a. Assume all applications begin with the highest possible number of points, 

i.e., 100 points, and points are subtracted for related weaknesses in their 

response to the criterion and sub-criterion;

b. Assume all applications begin with the lowest possible number of points, 

i.e., zero points, and add points based on the quality of the response 

provided for each criterion and sub-criterion; or

c. Assign points based on a rubric that describes the range of points that 

may be awarded in correlation to the quality of a response provided under 

a criterion or sub-criterion.

1) For example, program offices could establish a scale for a range of 

points for each quality level (e.g., “high,” “medium,” “low”) or 

description (“excellent,” “good,” “fair,” “poor,” etc.) for each selection 

criterion. Instructions and guidance for using these types of rubrics 

should be developed to enable peer reviewers to associate similar 

levels of quality with similar scores, thus promoting inter-rater reliability 

and consistency.

2) Program offices could use the following sample scoring range to 

improve inter-rater reliability. For a criterion with a maximum score of 
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20 points, peer reviewers might be guided to score a low-quality 

response from 1 to 7, a medium-quality response from 8 to 14, and 

high-quality response from 15to 20. These ranges act as anchors for 

peer reviewers to keep the scoring consistent across peer reviewers, 

even in instances where there is natural variability in scoring among 

different peer reviewers and across panels.

6. Program offices may develop detailed scoring rubrics for selection criteria that 

require factual answers to questions in order to ensure that all peer reviewers 

allocate points consistently when scoring the criteria. For these more detailed 

scoring rubrics (e.g., “to earn high points, an applicant must include [required 

information] in its response”), program offices establish the rubric through 

notice- and-comment rulemaking and publish the rubric in the Federal 

Register, unless an exception applies.

7. Program offices should also provide more specific guidance during the 

orientation and/or the panel review process but should ensure that the rubrics 

and instructions are not too complex or difficult to use, given the number of 

applications that peer reviewers are assigned and the time limits they have to 

complete their review.

D. Other Pertinent Information – Reserved

3.7.4 Peer Reviewer Oversight

A. Policy – Reserved

B. Procedures – Reserved

C. Guidance

1. The Competition Manager may engage in the types of oversight activities 

recommended to assist Panel Monitors as they perform the required review 

and assessment of the quality of peer reviewers’ scores.

2. The oversight activities below also help determine whether a contractor led 

panel requires the Competition Manager to participate on the panel to further 

explain or clarify program requirements, interpret the selection criteria or 

funding priorities, or provide additional instruction on other areas of review 

requiring discretion.

a. Evaluating scores and comments informally before and during the review 

process:

1) Panel monitors should review early drafts of peer reviewer comments 

to determine whether scores seem aligned with scoring guidance and 

instructions and comments are sufficiently detailed to justify scoring 
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decisions. Panel monitors can also use this early review as an 

opportunity to clarify any misunderstandings about the program’s 

selection criteria and priorities.

b. Ensuring the alignment of a peer reviewer’s comments with the assigned 

scores:

1) Ensuring that peer reviewers provide clear, concise, and constructive 

comments that reflect the scores assigned is critical to helping program 

offices determine which applicants have addressed the selection 

criteria best and, therefore, merit being included in the Grant Funding 

Slate.

2) This correlation of scores and comments by the peer reviewers also 

helps to demonstrate that the peer reviewers have carried out their 

duties as desired and have read the applications assigned to them 

thoughtfully and carefully.

3) The goal of this correlation of peer reviewer comments and points 

awarded for a selection criterion is to avoid the reality, or even the 

appearance of, peer reviewers’ arbitrary assignment of scores to 

applications.

a) For example, where a peer reviewer awards only a few points for a 

selection criterion, Panel Monitors would expect to see comments 

that discuss a greater number of weaknesses or flaws than any 

strengths they found. Conversely, peer reviewers who award the 

full number of points would be expected to have written comments 

that identify many strengths found in the section of the application 

and no weaknesses.

4) Similarly, Panel Monitors should evaluate reviewers’ comments to 

determine that they have not made outright errors in their reviews, 

such as asserting, that an application is missing required information 

(e.g., in response to a selection criterion) when, in fact, it is present.

c. Fostering informed panel discussions -

1) By having panel members discuss, as a group, each application and 

by paying close attention to the quality of those discussions, Panel 

Monitors should be able to better assess the level of each peer 

reviewer’s understanding of the review process and the selection 

criteria.

2) The panel discussion also allows each peer reviewer to consider the 

perspective of other peer reviewers in reaching their individual 

conclusions and provides the peer reviewers a common, general 
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understanding (as opposed to agreement by consensus) of the 

spectrum of quality of applications reviewed by the panel.

3) There will be instances where very qualified peer reviewers will 

honestly and objectively come to different conclusions about the quality 

of a given application. In these cases, it is possible that there will be 

noticeable variations in scoring among the peer reviewers.

4) Panel Monitors should encourage peer reviewers to explain their 

positions. After each peer reviewer has shared his/her perspective on 

the application’s merits, peer reviewers can then determine, 

independently and on their own, if any adjustments to their scores are 

warranted. One or more reviewers might decide to change their 

scores, having the potential result of bringing the scores of those peer 

reviewers into closer alignment with the scores of other reviewers on 

the panel.

d. Panel Monitors ensure that peer reviewers are not coerced into changing 

their scores. Should a problem arise, the Competition Manager should be 

consulted and could even be brought into the discussion. Having 

alternate peer reviewers available for circumstances that require them is a 

best practice and is highly recommended.

1) Panel Monitors, in rare instances, might find that a specific peer 

reviewer is unable to score applications according to the requirements 

and selection criteria applicable to a competition, despite repeated 

interventions by the Panel Monitor and/or Competition Manager.

a) In such an event, obtaining high-quality scores for the applications 

on a timely basis may be best achieved by removing the peer 

reviewer from the process and re-assigning the complete sub-group 

of that peer reviewer’s assigned applications (both scored and not 

scored) to a replacement peer reviewer.18

3. When Competition Managers create a peer reviewer roster for a competition, 

recruiting alternate peer reviewers facilitates a smooth transfer of such a subgroup of applications, so that the program can receive a timely review of them 

with the desired level of quality, in accordance with the requirements of the 

competition.

a. For such occasions, Competition Managers might want to focus 

particularly on recruiting those peer reviewers already experienced in 

working with ED programs. Whatever the alternate peer reviewers’ 

backgrounds, the needs of the competition will probably best be served by 

18 Peer reviewers can be removed for other reasons beyond the scope of this section. See the 

“Application Reviewer Standards or Expectations” section for additional discussion of this topic.
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recruiting those who agree to take part in initial peer reviewer orientation, 

whether the need for their services might arise.

D. Other Pertinent Information – Reserved

3.7. Peer Reviewer Evaluation

A. Policy

1. Program offices evaluate the performance of each peer reviewer after the 

application review process and use those evaluations to continually update 

the peer reviewer database.

2. Program offices use the sample template, Application Reviewer Evaluation, or 

other evaluation instrument as deemed appropriate by the program office, to 

ensure ED maintains a pool of reviewers that are professional, experts in 

various fields, and have demonstrated the capacity to engage in and 

understand all peer reviewer requirements and responsibilities.

a. Examples of these professional qualifications include the ability and 

expertise to fairly analyze and evaluate applications against the applicable 

selection criteria, write clearly and concisely, exercise effective time 

management, and strong interpersonal skills working cooperatively with 

others to ensure applications are reviewed in accordance with ED’s 

expectations.

b. The sample template, Application Reviewer Evaluation, is the same rating 

instrument as the Performance Assessment Form in e-Reader.

3. Program offices use peer reviewer evaluation results to maintain and recall 

for ED future reviews, peer reviewers that rate satisfactory or higher, or so 

other program offices do not recall peer reviewers who are deemed 

unsatisfactory.

B. Procedures

1. Program offices that use the grants management system for selecting peer 

reviewers use the Performance Assessment Form (Assessment Form) in the 

system to evaluate peer reviewers.

a. Program offices select the Assessment Form before setting up their 

panels, because the Assessment Form option will no longer be available 

after a panel has been formed.

b. Program offices that use their own proprietary system or a contractor for 

populating and maintaining peer reviewer databases implement protocols 
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to include peer reviewer evaluations and updates to peer reviewer 

databases.

2. Program offices, when selecting peer reviewers, comply with the section, 

Using Reviewers in Consecutive Application Review Cycles, to limit familiarity 

and ensure peer reviewers remain objective.

3. When selecting previous peer reviewers, program offices only select 

reviewers who, in accordance with their evaluations, previously performed 

satisfactorily or higher.

4. Competition Managers consult with Panel Monitors that are contractors to 

obtain information regarding the performance of peer reviewers and panel. 

Peer reviewer evaluations are completed only by ED staff.

5. Peer reviewer evaluations remain with the reviewer in the database, and 

available for others to review prior to selection of a reviewer.

C. Guidance

1. Program offices are encouraged to contact other program offices within ED 

that maintain their own reviewer pools outside of ED-wide grants 

management system in order to obtain available reviewers when peer 

reviewers in the system or in their own databases are exhausted. Similarly, 

program offices that maintain their own peer reviewer database or use a 

contractor are encouraged to reach out and/or share peer reviewers with 

other program offices.

2. Program office ratings that objectively assess the quality of the peer 

reviewers’ performance allow ED to maintain a peer reviewer database that 

consistently includes individuals who have demonstrated the capacity to 

engage in and understand all aspects of the peer review process.

D. Other Pertinent Information

1. Program offices can obtain a copy of the sample template, Application 

Reviewer Evaluation, by accessing the following link: Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. 

3.8 Multiple-Tier Application Reviews

A. Policy

1. Program offices, under the regulations in EDGAR § 75.224, have the option 

of using a multiple-tier review process to evaluate applications. In addition, 

certain programs have program regulations that specify the procedures for 

conducting a multiple-tier review.
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B. Procedures

1. Program offices, under EDGAR § 75.224, may refuse to review applications, 

in any tier, that do not meet a minimum cut-off score established for the prior 

tier.

a. The minimum cut-off score must be established either: 1) in the 

application notice published in the Federal Register; 2) after conducting a 

first-tier review and realizing the scoring range of applications; or 3) after 

reviewing the applications to determine the overall range in quality of the 

applications received.

2. Program offices, in any tier of the review, may use more than one group of 

experts to gain different perspectives on an application.

a. For example, program offices may choose to conduct a review of the 

proposed project design and management plan for each application first, 

and then move only the highest rated applications from that tier forward for 

a review of the evaluation plan (which would be conducted by a different 

set of peer reviewers).

b. Further, in any tier, program offices may refuse to consider an application 

if any of the groups in the prior tier scored it below the established 

minimum cut-off score.

c. When a multiple-tier review process is used as a means for narrowing the 

pool of applications that will be considered for funding, it would not be 

unusual for an application to receive a considerably different rating in the 

subsequent tiers (such as second or third tiers) than it did under the 

previous tier’s review, even from the same reviewers.

d. Although the reviewers in the subsequent tiers are still reviewing the 

applications under the same selection criteria, the applications are now 

being reviewed within the context of a higher quality pool of applications, 

still based on their own merit. For this reason, these differences in ratings 

do not indicate errors in judgment at the prior tier.

3. For some program offices, the last tier review may be conducted either by a 

discussion between the panel and each applicant, or by a second review of 

the application by the panel without the applicant’s involvement. When 

program offices intend to conduct a discussion with the applicants in the last 

tier, the ATRP must describe how the discussion will be conducted (i.e., 

describing whether the discussion will take place in-person, by 

teleconference, or using other technology). If the discussion will be held inperson, the ATRP must describe the travel arrangements that will be made 

for applicants to appear in person. Program offices publish information about 
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these interviews in the Federal Register. Program offices that wish to use this 

process consult with their program attorney.

4. Program offices include, in the ATRP, a description of the multiple-tier review 

procedures that will be used for the competition, including how or whether 

minimum cut-off score(s) will be established (see the section Contents of the 

ATRP).

C. Guidance

1. A multiple-tier review process involves the use of more than one review of 

an application or separate reviews for a pre-application and a full 

application in the same competition.

2. A multiple-tier review process is most used to narrow the pool of qualified 

applicants that will be considered for funding. For example, after the first 

level of review, only some of the applications are forwarded to the next tier 

for further consideration.

3. A multiple-tier review process might also be used to gain different 

perspectives on an application (e.g., within different tiers, a group of 

researchers and a group of practitioners might review an application 

relying on perspectives applicable to their respective professions).

D. Other Pertinent Information

1. The grants management system can support up to three tiers of review.

3.9 e-Reader – Peer Review System

A. Policy - Reserved

B. Procedures – Reserved

C. Guidance

1. Program offices before using e-Reader to conduct electronic peer reviews 

should take the related training to possess the necessary knowledge to use 

e-Reader.

2. Program offices are strongly encouraged to conduct the application review 

process electronically by utilizing e-Reader.

3. When using e-Reader, program offices should maximize its utility by using all 

its available features, which will allow for managing all aspects of the 

electronic application review process within one central location.
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4. Using e-Reader, and all its features, for electronic application review 

processes is beneficial because it allows for all information, entered or 

created, to be centrally stored and managed throughout all aspects of the 

electronic review by offering the following functionalities:

a. Allowing program offices to screen applications and to designate them as 

eligible, ineligible, or pending (i.e., pending for those that are neither 

eligible nor ineligible at the time of screening).

b. Allowing program offices to manage their pool of reviewers, including 

adding and deleting reviewers from the pool of reviewers.

c. Allowing program offices to develop and manage TRFs, including 

publishing the TRFs for selected reviewers to complete online.

d. Allowing program offices to develop and manage other review related 

forms, including the Reviewer Evaluation (completed by the panel 

monitor), Exit Assessment (completed by reviewers), Panel Assessment 

(completed by the panel monitor), Record of Discussion (completed by the 

panel monitor) and other applicable forms established for the grant 

competition to be reviewed.

e. Allowing program offices to establish and manage reviewer panels and 

their structures.

f. Allowing program offices to assign reviewers and applications to panels.

g. Allowing peer reviewers, panel monitors, and competition managers to 

participate in the application review and scoring process online.

h. Allowing program offices to select or remove reviewers from a grant 

competition review.

i. Allowing program offices to calculate rankings, using the raw scoring 

method or standardization scoring method, for a grant competition. Raw 

scoring uses average scores, and standardized scoring uses weighted 

scores.

j. Allowing reviewers to complete exit assessments.

k. Allowing Panel Monitors to evaluate reviewers and panels and allowing 

queries of these evaluations.

D. Other Pertinent Information

1. The grants management system Helpdesk is available as a resource to 

program offices and reviewers who may have questions about e-Reader. In 
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addition, there is an online demonstration in that provides detailed and useful 

information about e-Reader, using the system, and seeking technical 

assistance.
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Chapter 4: Pre-Award Activities 

4.1 Pre-Award Activities Applicable to All Programs - Introduction

The policy, procedures and guidance addressed in of this chapter are applicable 

to pre- award activities that are relevant to applications that fall within funding range. 

These activities are applicable to all ED discretionary grant programs. For activities 

that are applicable to only some of ED’s programs, see the Pre-Award Activities 

Implemented When Applicable section that follows in this chapter.

The pre-award phases of the discretionary grant process include all activities 

after the peer review process necessary for selecting applications. The information 

presented in this chapter helps to ensure that ED awards its grants fairly and 

consistently across principal offices. Specifically, this chapter focuses on:

1. Rank Order: Preparing a Preliminary Rank Order Based on Peer Review 

Scores; 

2. Application Reviews;

3. UEI Registrations Reviews - General;

4. Clarification Contacts;

5. Assessing Grant Application Risk Prior to Making New Grant Awards;

6. Reviewing Available Audit Data Prior to Making New Awards;

7. Key Personnel – Excluded Parties and Qualifications Review;

8. FAPIIS Information Review Requirements; and

9. Cost Analysis and Budget Review

4.2 Rank Order: Preparing a Preliminary Rank Order Based on Peer 

Review Scores

A. Policy

1. Program offices generate a rank order list of applications for funding following 

the review and score methods established in the ATRP. A rank order list of 

applications is based solely on the reviewers’ evaluation of the quality of the 

applications according to program-specific selection criteria or criteria 

identified in EDGAR § 75.210 (see EDGAR § 75.217 ©(i)), unless competitive 

preference points are assigned by peer reviewers and they factor into the 
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rank ordering. For related policy regarding who assigns competitive 

preference points see the section Orientation of Peer Reviewers. 

B. Procedures

1. Rank order lists are generated in e-Reader for competition reviews that occur 

in e-Reader; alternatively, scores are pulled into an Excel where formulas are 

run to generate the rank order list.

2. When competitions do not use the grants management system for their 

competition reviews, program offices enter the individual reviewers’ raw 

scores (after the reviewers complete their work) into the system following the 

review and score methods established in the ATRP in order to create a rank 

order list.

3. In limited circumstances the grants management system is not used to 

generate a rank order list. Instead, Program offices use Excel formulas to 

generate the rank order list.

a. When program offices use Excel formulas to generate the rank order list, 

they conduct a quality control review to ensure that scores are accurately 

entered into the grants management system. 

C. Guidance

1. Notwithstanding unique circumstances (e.g., when a review panel includes 

some reviewers who only score certain criteria, or when a multiple tier review 

consisting of more than 3 review levels is used, etc.), program offices, to 

reduce the chances for human error, should use e-Reader to generate rank 

order lists.

D. Other Pertinent Information

1. The system Helpdesk is available as a resource to program offices that may 

have questions about e-Reader.

4.3 Program Office Review of Applications

A. Policy

1. Program offices conduct a thorough review of each proposed applicant’s 

project activities and budgets before making funding recommendations to the 

Secretary to ensure that grantees receive funding that is both fair and 

adequate to the needs of their projects and that costs are allowable, 

allocable, and reasonable.
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2. Program offices review the budgets of applicants proposed to be funded 

before developing a Grant Funding Slate. Cost items, both Federal and nonFederal (i.e., cost sharing or matching funds) in an applicant’s proposed 

budget, must be related to specific project activities and must be allowable (2 

C.F.R. § 200.403), allocable (2 C.F.R. § 200.405), and reasonable (2 C.F.R. § 

200.404) in accordance with the cost principles in 2 C.F.R. 200 Subpart E and 

must conform to limitations under relevant Federal statutes and regulations.

3. ED may fund up to 100 percent of the allowable cost in an applicant’s budget 

(see EDGAR § 75.233). Program offices follow the process established for 

funding in the ATRP. ED may fund projects for less than their requested 

amounts as long as the lesser amount does not result in a change to the 

scope or objectives of the funded application (see the section Prohibiting 

Changes to the Project Scope or Objectives of a Grant).

B. Procedures

When reviewing applications, program offices:

1. Review and analyze both the proposed project activities and budgets for all 

years of the proposed project to determine whether the activities and budgets 

are allowable, allocable, and reasonable (see EDGAR § 75.232), and are 

submitted in accordance with the cost principles referenced in the section 

Budget Analysis and the Grants Management System– General. This also 

includes any non-Federal portion of the budget (see the section Grantee Cost 

Sharing or Matching (Non-Federal Share). 

2. Consider any concerns identified by reviewers on the TRF regarding 

proposed project activities or budget issues. 

3. Eliminate items that are not allowable from an applicant’s proposed project or 

requested funding level.

4. Ensure that any recommended changes to the proposed project activities or 

requested amounts do not change the project’s scope and objectives or 

impede the applicant’s ability to achieve the project’s intended goals or result 

in changes to the proposed project’s scope or objectives.

5. Consider comments received from State single points-of-contact (SPOC) 

under Executive Order 12372, Intergovernmental Review of Federal 

Programs, if applicable.

6. Ensure that the applicant has responded to the requirements under section 

427 of the General Education Provisions Act (see the section General 

Education Provisions Act (GEPA) – Section 427).
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7. Ensure that if an applicant indicated on the Application for Federal Assistance 

(SF424), Box 20, it was delinquent on a Federal debt and/or has a Federal 

judgment against it, program offices do not make an award until the applicant 

either pays the debt or enters into an agreement to pay the debt with the 

creditor agency.

8. Review for the required certifications and disclosures in accordance with the 

sections Certification of Eligibility for Federal Assistance in Certain Programs 

and Review of Lobbying Certification and Disclosure Form.

9. Conduct risk assessments for applicants recommended for funding and 

identify any risk mitigation strategies that will be implemented above and 

beyond those that are part of the program office’s routine monitoring and 

oversight procedures (see the section Evaluating Grant Applicant Risk Prior 

to Making New Grant Awards).

10.Review for compliance with 2 C.F.R. part 200 Subpart F, “Audit 

Requirements;” and review available audit information in accordance with the 

section Reviewing Audit Data Prior to Making New Awards. 

11.Review and consider information in FAPIIS before making awards that will, 

over the applicants’ performance period, exceed the simplified acquisition 

threshold addressed in OMB Memorandum M-18-18, “Implementing Statutory 

Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for 

Financial Assistance” available at: OMB Memoranda (see the section FAPIIS 

Information Review Requirements).

12.For projects that involve research, review whether or not the project’s 

research activities are exempt from the protections of human subjects’ 

requirements in accordance with the section Protection of Human Subjects 

Requirements. 

13.Review key personnel and related information, including reviewing for 

exclusions in SAM, in accordance with the section Key Personnel 

Qualifications Review & Excluded Parties List.

14.Use the Funding Recommendation Checklist, available at the link below, that 

will help ensure that all pertinent information has been considered and 

reviewed.

C. Guidance

1. Program offices may use the Funding Recommendation Checklist available at 

Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process to ensure all items listed in Procedures have been reviewed 

and considered. 
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D. Other Pertinent Information – Reserved

4.4 Unique Entity Identifier (UEI) reviews in SAM - General

A. Policy

1. Generally, applicants are required to submit their applications via Grants.gov, 

which requires an UEI active registration in SAM. Unless an applicant makes 

a timely request under the Common Instructions to file a paper application, or 

other unusual circumstances exist, an application that is not submitted via 

Grants.gov will not be considered for funding (see the Common Instructions).

B. Procedures

1. Throughout regular intervals in the grants management system, as program 

offices process grants and prior to obligation, program offices will be 

prompted to review SAM to ensure that an applicant’s UEI registration is 

active. Program offices should conduct these SAM reviews when prompted. 

a. The grants management system “refreshes” the registration status data 

from SAM daily.

b. An entity’s registration in SAM is either “Active” or “Inactive,” and the 

grants management system alerts program offices when a SAM 

registration is “Inactive” at the time the UEI is being verified.

2. When an applicant, that has an inactive SAM registration, has been 

recommended and approved for funding, program offices contact the 

applicant in accordance with the section Clarification Contacts for resolution 

and wait until the SAM registration status appears as active before obligating 

the grant, unless doing so would result in funds lapsing. (See the section UEI 

Registration Reviews in SAM – Pre-Obligation. 

C. Guidance – Reserved

D. Other Pertinent Information

1. For requirements in regulations addressing SAM registrations, see 2 C.F.R. 

Part 25. 

4.5 Clarification Contacts

A. Policy

1. Program offices contact applicants about technical issues—such as obtaining 

missing certifications, correcting errors in the budget calculations, or clarifying 

improperly labeled budget items—prior to awarding a grant. Such 
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clarifications occur as soon as program offices identify that a clarification is 

necessary. Initiating clarification contacts at this time will allow program 

offices to resolve issues prior to the development of Grant Funding Slates, 

thereby, eliminating the need to identify within the Grant Funding Slate any 

applications requiring clarification contacts and funding contingencies related 

to those applications

2. Clarification contacts focus only on seeking clarification, and may not result in 

the following:

a. The request for and submission of missing information that results in the 

application circumventing, or appearing to circumvent, the application 

deadline established for the competition in the NIA;

b. The submission of omitted information that was required to be submitted 

in the application to address the program’s selection criteria;

c. The submission of information that revises project activities that change 

the scope of work or objectives of the submitted application;

d. The submission of information that revises project activities and scope of 

work that are not authorized by the program’s statute, regulation, or 

priorities; or

e. The revisions of excessive (unreasonable) costs submitted in the 

application that, if reduced, would result in a change to the scope or 

objectives identified in the original application submission.

B. Procedures

1. As a general matter, clarification contacts are initiated before the funding 

Slate Memo has been submitted for review. When contacting an applicant for 

clarification, program offices must communicate through a disclaimer that the 

application is under review, and that the clarification contact is not an offer of 

funding. Program offices develop their own disclaimers or use the following 

disclaimer to explain that the clarification contact should not be misconstrued 

as an offer of funding.

2. We are completing routine preliminary reviews of grant applications that were 

submitted under the XXXX Program and have questions (listed below) about 

the information contained in your application (insert PR/Award number).

Please understand that this is not an indication that you are receiving an 

award, but merely that we need clarification regarding your application.

3. Program offices that choose to initiate clarification contacts after the Grant 

Funding Slate has been submitted, address the following in the Funding 

Slate:
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a. Mark the applications in need of a clarification contact with an asterisk to 

reflect that funds will not be committed until the outstanding technical 

issues are resolved.

b. Information on the technical issues that require clarifications, the 

acceptable resolutions, and identify the next applicant, in rank order, to 

fund in the event the technical issue cannot be resolved.

c. If program offices receive satisfactory technical information from the 

applicant, they inform the individual responsible for committing funds to 

proceed with commitment.

4. If the information submitted by the applicant is unsatisfactory, program offices 

inform the individual responsible for committing funds to withdraw the 

recommendation to fund the application, stating the reasons why it will not be 

funded and proceed to the application previously identified on the rank order 

list that may be selected with the funds made available (see the Grant 

Funding Slate Template for requirements and guidance about what to include 

when withdrawing the recommendation to fund an application).

5. If more serious issues such as applicant eligibility surfaces at this stage, 

program offices consult with their program attorney and address issues of 

eligibility prior to the development and approval of the Grant Funding Slate 

(see the section Receiving and Screening Applications).

C. Guidance

1. Program offices may have more serious questions regarding a recommended 

applicant’s budget or activities that must be resolved prior to awarding the 

grant. Contact with the applicant to clarify these issues and questions may 

occur prior to the development of the Grant Funding Slate and before the 

applications are selected for funding.

2. If program offices prefer for clarification contacts to occur after approval of the 

Grant Funding Slate, rather than before the Grant Funding Slate has been 

developed and approved, program offices may initiate the clarification contact 

after the Grant Funding Slate has been approved and the application has 

been selected for funding (see EDGAR § 75.231).

3. Examples of the types of issues that may require clarification contacts are 

presented below. This list represents some types of issues program offices 

may need to address with applicants during clarification contacts; thus, it is 

not meant to be interpreted as an exhaustive list.

a. An applicant has identified travel costs for three conferences. The 

justification for two provides sufficient detail to be deemed permissible in 

accordance with the program’s statute, regulations, or absolute priority. 
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The third conference, representing a significant amount of the 

application’s travel budget, appears to be allowable, but lacks the same 

level of detail as provided for the other two conferences making it difficult 

for program offices to definitively determine the appropriateness of 

including the cost of the conference in the application budget. Program 

offices may contact the applicant for clarification about the purpose for 

attending the conference and the costs associated with the conference.

b. An applicant is required by statute to recruit participants into training 

programs funded by the grant, and the applicant has identified how it will 

recruit participants from regions required to be targeted by the program’s 

statute, regulations, or absolute priority. The applicant has provided a 

detailed plan addressing recruiting effort for all required regions resulting 

in high program competition reviewer scores and a high rank ordering, but 

one region’s plan has been identified by the competition reviewers as less 

detailed than the others. Program offices may contact the applicant for 

clarification regarding the efforts to recruit participants from the region with 

the less detailed plan in order to determine if a specific award condition, or 

post award action, such as increased monitoring or TA, will be necessary.

c. An applicant has within its application proposal identified a project director 

by name and has included his/her vitae (or resume) in the application, but 

within the application budget narrative, an individual other than the 

individual identified in the application proposal is identified. Program 

offices may contact the applicant for clarification about this discrepancy. 

d. A program office is funding down the previous year’s approved slate. 

Program offices contact the applicants identified in the approved slate to 

determine if the applicant still has the capacity to carry out the scope of 

work and implement the grant project identified in the submitted 

application. 

4. Program offices should document any funding clarification contact that has 

taken place with an applicant and include a written summary of the discussion 

in the official grant file (see the section The Official Grant File). 

D. Other Pertinent Information – Reserved

4.6 Evaluating Grant Applicant Risk Prior to Making New Grant 

Awards

A. Policy

1. Program offices, before making new grant awards, conduct risk assessments 

(including, but not limited to, risk assessments related to available audit 

information, key personnel, applicants’ competencies, and FAPIIS 
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information) for applicants recommended for funding prior to submitting the 

Grant Funding Slate for review and approval.

2. In accordance with 2 C.F.R. § 200.206, when conducting a risk evaluation; 

program offices consider:

a. The information available through any OMB-designated repositories of: 1) 

government wide eligibility; 2) qualification; or 3) financial integrity 

information;

b. The criteria described in the application notice that is to be used to 

evaluate an applicant’s risk;

c. Prior and/or current financial information (e.g., bankruptcy, default rates,

draw down activity, lack of internal controls, improper payments, lack of 

procurement standards, previously closed out in noncompliance etc.) and 

performance information, including information in the grants management 

system; 

1) Compliance with Federal audit requirements, audit findings, progress 

in achieving corrective actions set in place to resolve audit findings, 

compliance findings; and

2) Other administrative issues to determine if any risk mitigation 

strategies above and beyond those that are part of the program office’s 

routine monitoring and oversight procedures are necessary to mitigate 

any risks that have been identified.

3. If a risk is identified and it has been determined appropriate to impose specific 

award conditions to address the identified risks (see the Procedure, 

Guidance, and Other Pertinent Information sections that follow below), the 

GAN includes notification, in accordance with 2 C.F.R. § 200.208 ©, of the 

following:

a. The nature of the additional requirements;

b. The reason why the additional requirements are being imposed;

c. The nature of the action needed to remove the additional requirements, if 

applicable;

d. The time allowed for completing the actions, if applicable, and

e. The method for requesting reconsideration of the additional requirements 

imposed. 
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B. Procedures

1. Program offices contact an applicant for clarification if further information is 

needed to assess a risk issue. During this clarification contact, program 

offices indicate that the application is being reviewed, but do not indicate that 

it will be funded. Language to be used by program that explicitly 

communicates this is found in the section Clarification Contacts. 

2. When program offices decide to impose specific award conditions to address 

identified risks, the specific condition must be reviewed and cleared by their 

program attorney.

3. Specific conditions are included on the GAN, including adding this standard 

language allowing for a reconsideration of the specific conditions imposed:

4. If you wish to request reconsideration of these specific conditions, please 

send written notification describing why such conditions should not be 

imposed on this grant to the ED Program Contact in Block 3.

5. If program offices learn, by accessing the Federal Audit Clearinghouse (FAC), 

the Entity Risk Review (ERR), or other resource, that an applicant seeking a 

new award failed to file an audit with the FAC in any prior year as required by 

2 C.F.R.§ 200.501, or they cannot confirm that an applicant has complied with 

its obligation to file the required audit, program offices place a risk-related 

condition on the GAN requiring the submission of the missing audit. Refer to 

the document Guidance and Decision Tree on Risk Mitigation When 

Applicants are Missing Single Audits, which includes OGC approved actions 

and specific conditions.

6. A copy of the GAN containing risk-related specific conditions and any 

associated cover letter is included in the official grant file. This occurs 

automatically in the grants management system when GANs are issued 

electronically.

7. Once the program staff and program official have determined that the specific 

conditions have been satisfied, or the problems or risks that led to the specific

conditions on the GAN have been resolved, program staff:

a. Issue a new GAN without the specific conditions;

b. Issue a GAN cover letter to the grantee explaining that the specific 

conditions have been removed from the award; and

c. Include a copy of the amended GAN and cover letter in the official grant 

file. This occurs automatically in the grants management system when 

GANs are issued electronically.
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8. In accordance with 2 C.F.R. §§ 3474.10, if the specific conditions under 2 

C.F.R. § 200.208 are designated as “high-risk” conditions and a high-risk 

designation is imposed, program offices refer to the section Grant 

Performance – Addressing Risk and Other Issues to review how to impose 

and remove a high-risk designation.

C. Guidance

1. The following list identifies several issues that program staff may consider as 

they conduct risk evaluations for applicants. The list is not all-inclusive, and 

program offices may identify additional items for consideration as they 

conduct risk assessments:

a. Is the applicant a novice applicant?

b. Is the applicant associated with a high-risk entity?

c. Did the applicant have a previous award with ED? If so, was the previous 

award closed in noncompliance?

d. Are there budget item concerns (unallowable and/or unreasonable costs) 

identified in the application project budget?

e. Do the data provided in the Entity Risk Review (ERR) reveal risks or a 

potential for risks?

2. In addition to considering information and results from the application review 

process, program offices may consider data provided in the ERR when 

assessing risk. Program offices may consider data provided in the ERR 

during monitoring. The ERR contains data from original sources such as 

SAM, the grants management system, the Federal Audit Clearinghouse, and 

the Adverse Accreditation Actions list distributed by the Office of 

Postsecondary Education (OPE).

3. The ERR is meant to:

a. Inform ED’s grant administration, oversight, and monitoring using a 

standardized set of risk indicators.

b. Facilitate program offices’ efforts to analyze grantee risk prior to making 

awards and during the life of a grant project.

c. Make single audit findings and other information about organizations’ 

fiscal health available and accessible to program offices.

d. Facilitate data sharing across grant programs and among ED offices.
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4. Program offices should generate ERR reports prior to, and as close as 

possible, to submitting the funding slate for review.

5. If a risk is identified, and it has been determined that the potential grantee 

might experience performance and/or financial management problems, it may 

be deemed appropriate to impose specific award conditions to address the 

identified risks, as established in the section Enforcement.

6. Prior to imposing specific award conditions, program staff should discuss an 

appropriate risk mitigation strategy with their program official, and their 

program attorney, and subsequently implement the strategy deemed 

appropriate to mitigate the identified risk.

7. In accordance with 2 C.F.R. § 200.208, a program official may impose 

specific award conditions to address the identified risks, as is established in 

the section Enforcement. 

8. In addition to including a specific condition on the GAN as addressed in 

Procedure item 4, program offices may address the missing audit during the 

post-award performance conference, which should be held within 30 days 

after issuing the GAN.

9. In addition to including specific conditions on the GAN to address high-risk 

issues as is required in the Procedures section, program officials may include 

a GAN cover letter, which may be drafted in the grants management system, 

to the grantee that explains the conditions or actions required under the grant 

award.

10.Program offices should consider conducting risk assessments for applicants 

recommended for funding as close as possible to submitting the Grant 

Funding Slate for review and approval.

D. Other Pertinent Information

1. The standard risk conditions available for GANs when an applicant seeking a 

new award failed to file an audit with the Federal Audit Clearinghouse in a 

prior year as required in 2 C.F.R. § 200.501, or when it cannot be confirmed 

that an applicant has complied with its obligation to file the required audit, are 

found in the Guidance and Decision Tree on Risk Mitigation When Applicants 

are Missing Single Audits document.

2. High-risk information is recorded in the grants management system’s Risk 

Module, so that information is easily shared across ED principal offices.

3. The ERR is available on the Self-Service ERR site in EDISON, which 

provides self-service, online, interactive, and real-time access to ERR data. 
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For access to the Self-Service ERR site, program offices can request an 

account using the following link: EDISON. 

4. Program staff can ask an ERR question via EDISON@ed.gov, or the ERR

contact list. 

4.6.1 Reviewing Audit Data Prior to Making New Awards

A. Policy

1. Program offices review available audit information before making new 

awards.

2. Single or program specific audits are required for entities expending Federal 

assistance equal to or in excess of $750,000 during the entities’ fiscal years 

(see 2 C.F.R. § 200 Subpart F).

B. Procedures

1. If program offices’ review of audit data, from the ERR, Federal Audit 

Clearinghouse (FAC) or other resource, reveals that an applicant has failed to 

comply with the filing requirement or they cannot confirm that an applicant 

has complied with its obligation to file the required audit, program offices 

place a specific condition on the GAN requiring the submission of the missing 

audit. Program offices use the document Guidance and Decision Tree on 

Risk Mitigation When Applicants are Missing Single Audits which includes 

OGC approved actions and specific conditions.

2. Program offices follow up with the applicant if the applicant has filed an audit 

report that reveals findings to assess if the findings have been resolved. 

Program offices initiate follow-up in accordance with the section Clarification 

Contacts. Program offices consult with their POC’s audit liaison and the 

appropriate audit resolution staff member in the Audit Resolution Division 

(ARD) to verify information received from the applicant and obtain additional 

information regarding the status of the findings.

3. Program offices, in the event findings are unresolved, follow policy in the 

Handbook for External Post Audit Process and follow applicable procedures.

4. Program offices contact an audit resolution staff member in ARD to discuss 

the status of findings, access/obtain Program Determination Letters (PDLs), if 

applicable, and discuss appropriate resolutions with ARD for issuance of 

PDLs and follow other applicable procedures. In some cases, program offices 

may need to recommend that the program official impose specific conditions 

on the grant and may recommend a heightened level of monitoring and 

technical assistance.
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5. Program offices document in the official grant file all actions taken to bring the 

grantee into compliance with the requirements of 2 C.F.R. § 200 Subpart F. 

C. Guidance

1. To review audit data, program offices may use any of the following databases 

or tools: 

a. the Federal Audit Clearinghouse (FAC) database; 

b. the ERR; or

c. other means established as beneficial by program offices for reviewing 

audit information. 

2. The ARD maintains updated lists of grantees with missing audits. The list and 

link to ARD’s SharePoint site where the lists are posted are sent to Executive 

Officers and Audit Liaison Officials in program offices at least twice a year.

D. Other Pertinent Information

1. Audit policy can be found in the Handbook for External Post Audit Process

2. The Risk Management Resources site contains the ARD contact list

4.6.2 Key Personnel Qualifications Review & Excluded Parties List

A. Policy

1. Program offices ensure that applicants designate, at a minimum, the project 

director and/or principal investigator as key personnel.

2. Program offices, in accordance with 2 C.F.R. § 3485, must conduct a review 

of the SAM Exclusions list for designated key personnel, the authorized 

official, as well as the applicant.

3. Applicants are responsible for defining and identifying all other key personnel 

positions in their applications.

B. Procedures

1. Program offices review resumes of all key personnel, as well as qualifications 

identified in project descriptions of key personnel to be hired, to ensure the 

applicant has the expertise and experience to successfully achieve the project 

goals and objectives.

2. Program offices access the SAM Exclusions list, which contains the names 

and other information about persons who are debarred or suspended from 
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participation in Federal programs and are ineligible to do business with the 

Federal government, to verify that the applicant, the authorized official, or 

identified key personnel are not on the list (see 2 C.F.R. § 180).

3. If applicants or any key personnel appears on the SAM Exclusions list, 

program offices must contact their GMPD liaison with the name and any 

related information before proceeding. The GMPD liaison validates the 

identity and advises the program staff of any issues and on how to proceed.

4. Program offices review the SAM Exclusions List for key personnel hired after 

the award is made or whenever changes are made to key personnel (see the 

section Changes to Key Personnel).

C. Guidance

1. Program offices do not select key personnel from among competing 

individuals on behalf of grantees, and their review of a grantee’s key 

personnel focuses only on ensuring that the key personnel the grantee hires 

possess the experience, qualifications, and skills necessary to ensure that the 

grantee achieves the scope or objectives of the project and its outcomes.

2. Although concerns about key personnel expertise and experience should not 

prevent a project from being funded, these concerns can be addressed with 

the applicant/grantee and may inform monitoring of projects.

3. Factors program offices may use in determining whether those hired for a 

grant project would be covered by the concept of key personnel include:

a. Whether the person’s participation has direct bearing on the outcome of 

the project;

b. Whether the person bears substantive responsibility for developing or 

achieving the scope or objectives of the project;

c. Whether the person possesses the experience, knowledge, or skills that 

the project requires; and

d. Whether the individual is identified in the application and that person’s 

qualifications are relevant to a criterion for selecting the grantee.

4. In most cases, the designation of key personnel would apply only to a small 

number of positions in a grant project. Principles to consider are as follows:

a. In many cases, key personnel on a project are permanent staff members 

of the institution, organization, or educational agency that receives 

funding. However, ED policy does not exclude consultants or temporary 
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staff members with essential expertise or skills when they are specifically 

identified in the application as working on or advising the project.

b. Generally, the term “key personnel” would exclude supporting staff, such 

as administrative or special assistants, and rarely, if ever, include clerical 

personnel.

c. When applying requirements of ED policy and/or regulations for key 

personnel to individuals of a grantee’s staff, program offices should first 

look at the persons and/or positions named by an applicant in response to 

a selection criterion for key personnel. This criterion can be found in 

EDGAR § 75.210 (e) or in program regulations that govern selection of 

grantees for a particular discretionary grant competition.

d. Subordinate personnel may occasionally fall within the scope of key 

personnel when they have responsibility for a major component of a 

project (such as activity directors, team coordinators, co-investigators or 

co-directors of project components at consorting institutions or 

organizations).

5. Program offices, in all communications regarding key personnel staff, ensure 

that grantees understand that they, not ED, select key personnel to hire from 

among competing individuals.

D. Other Pertinent Information

1. Grantees perform the SAM Excluded Parties List review for their contractors, 

consultants, and subgrantees, not ED staff.

4.6.3 Determining Applicant Competence and Responsibility

A. Policy

1. ED policy requires grant recipients to be competent, responsible, and 

committed to achieving the objectives of the awards they receive.

2. Program offices do not make an award to an applicant that is debarred or 

suspended unless it has received an exception under 2 C.F.R. § 3485.137. 

B. Procedures

1. Program offices, when reviewing applications being recommended for 

funding, must consider the following factors in determining an applicant’s 

ability to carry out the proposed project activities responsibly:

a. The financial stability of the applicant;
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b. The applicant’s previous experience, if any, in administering Federal 

grants;

c. Whether the applicant has adequate internal, fiscal and administrative 

controls (see 2 C.F.R. §§ 200.302; 200.303; and 200.305);

d. Whether the applicant is suspended or debarred;

e. The applicant’s performance under other ED awards (see EDGAR § 

75.217(d)(3)(ii)); and

f. Any adverse information regarding the applicant’s officials or key 

employees that calls into question their ability to perform satisfactorily.

2. If program offices find evidence of problems related to the factors identified 

under the item 1 above, or there appear to be issues with the applicant’s 

competence and commitment to achieving the objectives of the awards, they 

must recommend that the program official take one of the following actions:

a. Delay the award until the conditions are corrected;

b. Deny the award;

c. Make the award with specific award conditions (see the section 

Enforcement); or

d. Designate the applicant as “high risk” (see the section Grant Performance 

– Addressing Risk and Other Issues) and make the award with specific

award conditions.

3. Program offices contact their GMPD liaison to share their concerns when the 

applicant’s ability to perform is questionable, or if the applicant’s conduct 

otherwise appears to meet the standards for debarment and suspension (see 

2 C.F.R. § 180 and 2 C.F.R. § 3485). Once all relevant information has been 

gathered, GMPD will work with OGC and program offices for resolution.

4. If program offices identified concerns with any factors identified in item 1 

above and that applicant is subsequently recommended for funding, the Grant 

Funding Slate contains an analysis of those concerns and a justification for 

the funding recommendation.

C. Guidance – Reserved

D. Other Pertinent Information 

1. The GMPD Grant Policy Liaisons list is at GMPD Liaisons 
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4.6.4 FAPIIS Information Review Requirements

A. Policy

1. Program offices review and consider information about applicants in FAPIIS if 

the grants exceed or will exceed, over the course of the discretionary grant 

project periods, the simplified acquisition threshold. This review is conducted 

before making new awards that exceed the simplified acquisition threshold. 

Currently, this threshold is $250,000.

2. Before awarding a grant, program offices, at a minimum, determine that the 

FAPIIS information: 1) demonstrates a satisfactory record of executing 

programs or activities under Federal grants, cooperative agreements, and 

procurement awards; and 2) demonstrates integrity and good business ethics 

(see 2 C.F.R. § 200.206).

3. Program offices record the FAPIIS review in the official grant file for those 

applicants awarded a grant.

4. When not making an award because of information in FAPIIS, program 

offices notify applicants that the award will not be made based on: 1) an 

unsatisfactory record of executing programs or activities under Federal 

grants, cooperative agreements, and procurement awards; or 2) 

unsatisfactory information related to the applicant’s integrity and its business 

ethics (see 2 C.F.R. § 200.206).

5. Program office notifications to applicants explain that the determination to not 

make the award has been entered into FAPIIS, and that the information will 

remain in FAPIIS for five years from the date of the determination (see 2 

C.F.R. § 200.213).

B. Procedures

1. The ED grants management system prompts program offices to review 

FAPIIS information prior to making an award at the UEI verification screen. 

Reviews are conducted in FAPIIS by entering the applicant’s name or UEI 

number in the appropriate search fields.

2. If program offices find unsatisfactory information in FAPIIS about the 

applicant, the program may, after consultation with their program attorney, 

decide to make an award if, the information is determined to not be relevant 

to the Federal award under consideration, or if there are specific conditions 

that can be applied to the award that will appropriately mitigate the effects of 

the risk presented by the applicant.

3. Whenever specific conditions are applied to an award made to an applicant 

that would otherwise be deemed unqualified, ED is not required to report the 
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determination that the applicant is not qualified to receive an award in FAPIIS, 

since the inclusion of the specific condition is intended to mitigate the risk 

presented by the entity.

4. Program offices record in the official grant file or the competition file that 

FAPIIS reviews were conducted according to the following:

a. If an applicant is awarded a grant, program offices record in the official 

grant file that the FAPIIS review was conducted.

b. If an award is made after it was determined that specific conditions would 

mitigate the effects of risks associated with information available in 

FAPIIS, program offices file the decision to award the grant and the GAN 

reflecting the applicable specific conditions in the official grant file. When 

an award is made to an entity that would otherwise be deemed 

unqualified, specific conditions are applied in accordance with 2 C.F.R. § 

200.208 and 2 C.F.R. § 200.213. 

c. If an applicant is not awarded a grant based on a FAPIIS review and 

consultation with their program attorney, program offices record in the 

competition file the date of the FAPIIS review and the results of the review

and notify the GMPD FAPIIS Reporting Point of Contact who will report 

the decision to FAPIIS.

1) Within 48 hours after the notification has been issued, program offices 

forward to the GMPD FAPIIS Reporting Point of Contact a copy of the 

notification sent to the applicant, and any available supporting 

documentation.

2) The GMPD FAPIIS Reporting Point of Contact reports to FAPIIS the 

program office’s determination to not fund a grant.

C. Guidance

1. FAPIIS reviews are likely to yield the best results when searches are 

conducted by entering the applicant’s or grantee’s UEI number in the 

appropriate search field, or by conducting a UEI number search and a name 

search.

2. In cases where program offices determine the risk is sufficiently high to deny 

funding, program offices may use the notification titled FAPIIS Notification 1 

(or a derivative of FAPIIS Notification 1 that best meets the needs of the grant 

program as agreed to by program staff and the program attorney) when 

communicating to an applicant that it will not be awarded a new grant based 

on FAPIIS information.
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D. Other Pertinent Information

1. The simplified acquisition threshold is addressed in OMB Memorandum M-18-

18, “Implementing Statutory Changes to the Micro-Purchase and the 

Simplified Acquisition Thresholds for Financial Assistance” available at OMB 

Memoranda. The simple acquisition threshold is periodically adjusted for 

inflation in accordance with 41 U.S.C. § 1908, “Inflation Adjustment of 

Acquisition-Related Dollar Thresholds.”

2. FAPIIS reviews may not yield any information, and this serves as affirmation 

that the grantees’ FAPIIS records are clear of adverse reporting.

3. The GMPD FAPIIS Reporting Point of Contact can be found at the following 

link: GMPD FAPIIS Reporting Point of Contact. 

4. The FAPIIS Notification 1 is available at the following link: Documents and 

Forms Referenced in the Handbook for the Discretionary Grant Process. 

4.7 Certification of Eligibility for Federal Assistance in Certain 

Programs

A. Policy

1. Individuals who are recipients of Federal grant funds, either directly from ED 

or indirectly through another entity (e.g., an ED grantee), must certify, in 

accordance with EDGAR § 75.60 – § 75.62, that: 1) they are not in default on 

Federal debts, or that they have made satisfactory arrangements to repay 

defaulted debts; and 2) they are not ineligible to receive Federal funds during 

the period of the anticipated funding as a result of conditions of sentencing 

imposed by a judge under Title 21 U.S.C. Controlled Substances Act, Part D 

Section 862.

2. Program offices inform applicants when they apply for assistance as 

individuals, either directly to ED or indirectly through another entity, of the 

obligation to address the required certifications in their grant applications by 

completing the form Certification of Eligibility for Federal Assistance in Certain 

Programs, ED 80- 0016.

B. Procedures

1. Program offices include the ED 80-0016 form in their application packages for 

grant programs that provide funding to individuals, either directly or indirectly 

through another entity;

2. Ensure, prior to award, that all grant applications contain a completed ED 80-

0016 when the recommended applicant is an individual applying directly to 

ED for assistance;
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3. Ensure, prior to award, that any entity recommended for funding has on file 

certifications from any individuals to whom grant funding from ED will be redistributed as indirect assistance (e.g., scholarships, fellowships, stipends, 

tuition); and

4. Include, in a grantee’s file, documentation that program offices have: 1) 

requested the certification from individuals who did not send it with the 

application; 2) discussed the certification requirement with entities that will 

redistribute grant funds as assistance to individuals; and 3) verified that 

entities have obtained certifications from individuals.

C. Guidance – Reserved

D. Other Pertinent Information

1. The ED 80-0016 is available at: Application Package Toolkit - Documents, 

Instructions, & Other Information. 

4.8 Review of Lobbying Certification and Disclosure Forms

A. Policy

Restrictions on the lobbying activities of applicants and recipients of grants and 

cooperative agreements are addressed in EDGAR Part 82, which:

1. Prohibits applicants and recipients of Federal grants and cooperative 

agreements from using Federal funds to lobby for any Federal grant or 

cooperative agreement.

2. Requires applicants for Federal grants or cooperative agreements exceeding

$100,000 to file a certification form (Certifications Regarding Lobbying Form) 

at the time the application is submitted. By completing this form, applicants 

declare that they have not, nor will they, use Federal funds to lobby for any 

Federal grant or cooperative agreement.

3. Requires applicants for Federal grants or cooperative agreements exceeding

$100,000 to submit the Standard Form (SF) LLL (Disclosure of Lobbying 

Activities), with their applications. This form is to be completed if the applicant 

has used non-federal funds to lobby for any Federal grant or cooperative 

agreement.

4. Requires recipients of subawards (i.e., subgrants or contracts) that are issued 

under Federal grants or cooperative agreements to comply with the same 

lobbying restrictions and certification and disclosure requirements as Federal 

grant applicants and recipients.
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5. Provides certain exceptions for Indian tribes and tribal organizations, 

professional and technical services, and agency and general liaison activities.

6. Allows for the imposition of civil penalties on applicants and grantees that do 

not comply with the requirements of the law.

B. Procedures

1. Program offices include in all discretionary grant application packages the 

“Certification Regarding Lobbying,” and the “SF-LLL, Disclosure of Lobbying 

Activities” forms.

C. Guidance – Reserved

D. Other Pertinent Information

1. The Certification Regarding Lobbying, and the SF-LLL, Disclosure of 

Lobbying Activities forms are available at: Application Package Toolkit - 

Documents, Instructions, & Other Information. 

4.9 Cost Analysis and Budget Review

4.9.1 Budget Analysis and the Grants Management System– General

A. Policy

1. Program offices ensure that cost items in an applicant’s proposed Federal 

and non-Federal budgets are related to specific project activities and that 

those costs are allowable, allocable, and reasonable in accordance with the 

Federal cost principles in 2 C.F.R. § 200 Subpart E. 

2. Prior to making funding recommendations for the approval of a slate, program 

offices conduct a cost analysis of the applicant’s budget to determine the 

amount of a new grant. If the application is for a multi-year award, a cost 

analysis is conducted for each year (see EDGAR § 75.232).

a. Program offices may consider requesting a waiver (see Procedures in the 

Applicability section) to review out-year budgets prior to issuing NCC 

awards, rather than before awarding funds for the first year of the grant, 

when a large volume of potential awards is likely to impede the timely 

processing of those awards. While under this scenario, a waiver could be 

requested for the approval to review out-year budgets prior to issuing NCC 

awards, program offices conduct a cost analysis and budget review for the 

year one awards prior to making those awards. For applications with initial 

budgets submitted with errors, unallowable costs or other items of 

concern, waivers will not be approved.
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3. Program offices, when reviewing specific cost items, determine whether the 

costs: 

a. Are necessary for the proper and efficient performance and administration 

of the grant project;

b. Conform to any limitation or exclusions set forth in any governing 

principles or regulations that apply to the types or amounts of cost items 

associated with the funded project;

c. Reflect generally accepted accounting principles;

d. Include indirect cost reimbursement in accordance with indirect cost policy 

(see the section Indirect Costs – General and other related indirect cost 

sections);

e. Are adequately documented and justified;

f. If charged as direct costs, are incurred specifically for the project; and

g. Are treated consistently with costs used for the same purpose in similar 

circumstances. 

4. Program offices do not allow a grantee to charge the grant a fee representing 

profit, even when the recipient is a commercial for-profit entity. This restriction 

does not apply to contracts awarded by a grantee.

5. In accordance with EDGAR § 75.233, an applicant’s budget must not be 

funded above the requested amount. To make an increase after an initial 

award has been made, program offices refer to the section Supplemental 

Awards.

B. Procedures

1. Program offices enter budget data for all requested/recommended budget line 

items (i.e., specific line-item amounts for Personnel, Supplies, Other, etc.) in 

the grants management system for each budget year within the project 

period.

2. Program offices check that the budget data identifies key personnel costs, the 

percentage of time key personnel will work on the project, and enter key 

personnel data (see the section Key Personnel Data and Level of Effort in the 

Grants Management System).

3. Program offices obtain and enter the grantee’s UEI number into the grants 

management system to process a new award. If the UEI number is missing 

from the application, program offices contact the applicant to obtain it. 
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Program offices, when attempting to save the applicant’s budget on the 

discretionary budget tab page, will be notified via a message if the applicant’s 

UEI number is associated with a high-risk grant or grantee. If the UEI number 

is associated with a high-risk grantee, program offices follow the policy and 

guidance in the section Grant Performance – Addressing Risk and Other 

Issues. 

C. Guidance

1. Program offices may have identified a budget item cost that is “unclear” (i.e. 

there is a lack of clarity in the budget and budget narrative). If time permits, 

program offices may contact the applicant in accordance with the Clarification 

Contacts section or address the issue during the post-award conference, and 

require the grantee to submit a revised budget, if necessary.

D. Other Pertinent Information – Reserved

4.9.2.Key Personnel and Level of Effort in the Grants Management 

System

A. Policy

1. Program offices enter in the grants management system the names, titles, 

and the percentage of time for the project director, principal investigator, or 

other designated key personnel.

B. Procedures

1. If a selected applicant has not submitted names, resumes, or qualifications for 

key personnel or included position descriptions for key personnel in the 

application, program offices address the matter with the applicant, and 

request the information as part of any revised materials that will be submitted. 

This information is obtained during the clarification contact (see the section 

Clarification Contacts). During this contact, program offices do not disclose 

that the application is being funded, but rather, that it is being considered for 

funding.

2. Program offices, when making a new award, enter the names, titles, and 

percentage of time devoted to the project, into “key personnel” of the 

discretionary budget. 

3. If key personnel have not been identified or hired under the grant at the time 

of application, program staff describe the position to be filled in the “Title” field 

and enters the term “Vacant” in the “Last Name” field. 

4. Program offices verify the percentage of time (level of effort) that each person 

occupying a key position will work on the project.
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a. The grants management system will search key personnel across all ED 

grants to ensure that a key person’s level of effort does not exceed 100 

percent. The system will issue an alert message if a key person’s level of 

effort exceeds 100 percent. If an alert occurs, program offices use the 

“inquire key personnel” option. This option provides information on other 

grant(s) that the key person is associated with, and his/her allocated 

percentage of time to each of those grants. ED contact information for all 

other grants the individual is associated with is also available within this 

option.

b. Program offices resolve the key person’s percentage of time (level of 

effort) issue accordingly:

1) If the key person works on grants under a full-time academic year 

appointment at an institution of higher education (IHE) (e.g., 9 months), 

and also works on grants during the remaining 3 months of the 

calendar year (for a total of 12 months), and the policy of that 

institution authorizes that such an employee’s level of effort across all 

grant projects may exceed 100 percent (i.e., the individual’s full-time 

academic year appointment plus the percentage of time for work under 

a grant exceeding the full-time academic year appointment), program 

offices move forward with processing the grant under this scenario as 

long as the level of effort across all grants that the key staff person is 

assigned to does not exceed the level of effort authorized in the 

institution’s policy.

2) If the key person works at an IHE that does not have a policy in place 

regarding staff allocations and levels of effort that may be devoted to 

grant projects, or the key person does not work at an IHE, program 

offices may determine, in consultation with other ED staff who are 

responsible for other grants on which the person is identified as key 

personnel, that a level of effort exceeding 100 percent is reasonable 

based on responsibilities under each grant, which is consistent with 2 

C.F.R. § 200.430. If program offices are having difficulty in reaching a 

resolution, they consult with their program official for assistance and 

next steps.

3) If, in consultation with ED staff responsible for the key person’s other 

ED grants, it is decided that the percentage of time the individual will 

devote to the grant in question or to other grants should be reduced, 

program offices ensure through clarification contacts, (see the 

Clarification Contacts) that the organization or institution employing the 

key person will make arrangements satisfactory to ED to reduce the 

individual’s percentage of time, and provide support and assistance to 

the key person in their duties, such that ED can be confident that the 
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work on all affected grants will be completed successfully, and in 

accordance with each grant’s scope of work.

4) If, in consultation with ED staff responsible for the key person’s other 

ED grants, it is decided that the organization or institution employing 

the key person will remove the person as key personnel from the grant 

in question or from one of their other assigned grants, program offices 

ensure that the organization or institution hires a qualified replacement, 

and that the replacement has agreed to conduct the grant as described 

in the approved application, and will provide the level of effort required 

to successfully complete the project.

5) In reaching a resolution of the level of effort issue, program offices 

responsible for grants on which the person was identified as key 

personnel consults with their Program Official, to obtain final approval 

of the resolution.

5. Program offices ensure that appropriate documentation reflecting the final 

approval of all changes to key personnel are maintained for each grant 

affected by the changes. The documentation is maintained in each official 

grant file, and includes the following: 1) an explanation of any changes to the 

key staff person’s budgeted levels of effort, if any, for each grant; 2) any 

changes to the budgeted levels of effort of other grant staff that are necessary 

to ensure support for the successful completion of the projects; and 3) any 

addition of new grant staff, and their budgeted level of effort, needed to 

ensure support for the successful completion of the project.

C. Guidance – Reserved

1. Program offices should review level of efforts that exceed 100% for key 

personnel, and approve these requests only in limited circumstances, 

particularly if the entity is not an IHE nor supported by institutional policy.

D. Other Pertinent Information – Reserved

4.9.3 Direct Costs

A. Policy

1. All direct costs chargeable to a grant must be allowable, reasonable, and 

specifically allocable to the grant activities and not otherwise recoverable as a 

reimbursement through the negotiated indirect cost rate.

2. Applicants charge all allowable costs directly to the grant if they:

a. Have only one Federal grant from one Federal agency;
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b. Have no other sources of revenue (such as State, local or private grants); 

and

c. Engage in no other activities (such as fundraising activities or other 

business development activities).

3. Applicants with multiple Federal grants and no other revenue sources must 

allocate all allowable costs that directly benefit the grants directly and 

proportionally to each grant.

B. Procedures

1. Program offices scrutinize the ED 524 Budget Information Form and budget 

narrative in a grant application by carefully reviewing all direct costs to ensure 

that they are allowable, allocable and reasonable.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

4.10 Pre-Award Activities Implemented When Applicable - 

Introduction

Unlike the preceding section, Pre-Award Activities Applicable to All Programs, 

the activities listed in this section may be applicable to only some of ED’s 

discretionary grant programs. When the sections that follow are applicable, program 

offices conduct budget analysis in accordance with the policy, procedures, and 

guidance addressed in the preceding section Budget Analysis and the Grants 

Management system- General. 

4.10.1 Grantee Cost Sharing or Matching (Non-Federal Share)

A. Policy

1. The policies governing grantee cost sharing or matching are below. Cost 

sharing or matching is the portion of project/program costs not borne by the 

Federal government. The terms are used interchangeably and refer to either:

a. A statutorily specified percentage of project/program costs that must be 

contributed by a grant applicant in order to be eligible for funding; or

b. Situations where the applicant voluntarily shares in the costs of a project 

consistent with the definition of voluntary committed cost sharing or 

matching in 2 C.F.R. § 200.1. This includes cost sharing or matching 

proposed under a competitive preference priority.
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2. There may be some costs from non-Federal sources that are not statutorily 

required and do not meet the definition of voluntary committed cost sharing or 

matching in 2 C.F.R. § 200.1. These costs should not be treated as cost 

sharing or matching.

3. In accordance with 2 C.F.R. § 200.306, voluntary committed cost sharing or 

matching under research applications or proposals is not expected and 

cannot be used as a factor during the merit review unless the selection 

criteria for considering voluntary committed cost sharing or matching is 

explicitly described in the application notice.

4. Any cost sharing or matching proposed by an applicant must be fully 

documented and accounted for within the application budget documents. 

Applications submitted for funding that have either required or voluntary 

committed cost sharing or matching must include:

a. The specific costs or contributions proposed to meet the cost sharing or 

matching requirement;

b. The source of the cost sharing or matching; and

c. In the case of in-kind contributions, a description of how the value was 

determined for the donated or contributed services or goods.

5. Program offices ensure that costs included in an applicant’s cost- sharing or 

matching budget meet the same standards as the Federal share (see 2 

C.F.R. § 200.306).

B. Procedures

1. When program offices require or encourage cost sharing or matching by 

establishing absolute or competitive preference priorities, this must be 

specified in the NIA. The NIA must indicate whether:

a. The cost sharing or matching is a fixed percentage or a minimum 

percentage;

b. The cost sharing or matching applies to each budget period or to the 

project period if deemed appropriate by the program official; and

c. There are any restrictions on meeting the cost sharing or matching 

through in- kind contributions.

2. Cost sharing or matching (non-voluntary or voluntary committed) must be 

submitted as the non-Federal share of the applicant’s budget, and program 

offices ensure that the cost sharing or matching amount is reflected on the 

GAN and any required terms and conditions are also included.
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a. For non-voluntary cost sharing or matching, a standard GAN 

term/condition will automatically appear on the GAN stating that the 

grantee must contribute the non-voluntary cost sharing or matching when 

program enters the non-Federal share in the grants management system. 

b. For voluntary committed cost sharing or matching consistent with 2 C.F.R. 

§ 200.99, program offices must select and include on the GAN the 

following clause that informs applicants selected for grants who volunteer 

cost sharing or matching where there is no requirement for it or who 

volunteer additional cost sharing or matching above that required by 

statute or regulation, that they must provide that level of volunteered cost 

sharing or matching as a condition of the award.

“The cost sharing or matching, as proposed by the grant recipient, has been 

accepted by the Department. The grant recipient is required to meet this cost 

sharing or matching contribution unless the grantee receives permission from the 

Department to reduce that contribution.” 

C. Guidance

1. For grant programs that do not have a statutorily specified cost sharing or 

matching requirement, a program official may require or encourage cost 

sharing or matching by establishing absolute or competitive preference 

priorities.

2. If cost sharing or matching is not required and a grantee fails to meet its 

commitments in its application, the failure to meet the commitment will likely 

be analyzed in terms of whether the applicant is failing to meet the scope and 

objectives of its grant. Program offices should consider these situations on a 

case- by-case basis and should consult with their program attorney.

D. Other Pertinent Information

1. Guidance regarding the valuation of a grantee’s cost sharing or matching 

contribution is addressed in the document titled, “Valuation and 

Documentation of Grantee Cost Sharing and Matching Contributions,” which 

is available at: Documents and Forms Referenced in the Handbook for the 

Discretionary Grant Process. 

2. Grantees are required to report their cost sharing and matching expenditures 

in their annual Grant Performance Report (ED 524B), if applicable, and in 

their final performance report at the end of the award. The ED 524B is 

available at: Grant Application and Other Forms

3. Grant programs that do not use the ED 524B have grantees report their cost 

sharing or matching expenditure information on the Federal Financial Report 

(FFR) form.
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4.10.2 Waiving Required Cost Sharing or Matching

A. Policy

1. With the Secretary’s approval, program offices may waive an applicant’s cost 

sharing or matching required in a program’s statute or regulations when the 

statute or regulations provide such authority.

2. Applicants may request a waiver to for some or all required cost sharing or 

matching when the program’s statute or regulations provide such authority, 

and applicants can justify their request to the satisfaction of the ED for a 

waiver.

3. Unless well-justified by the applicant, the Secretary does not, as a general 

matter, waive cost sharing or matching due to the importance of required cost 

sharing or matching to the long-term success of a grant project.

B. Procedures

1. Program offices announce in their NIAs requirements for waiver requests 

when the applicable program’s statute or regulations state the authority to 

waive program requirements.

2. Applicants submit requests for waivers of required cost sharing or matching in 

their applications that explicitly justify the need for a waiver and limit their 

requests to any waiver requirements set out in the program’s statute or 

regulations, whenever any such requirements exist (e.g., if the waiver 

authority allows for some but not all of the required cost sharing or matching 

to be waived, the waiver request must be submitted accordingly).

3. The recommendation to waive an applicant’s required cost sharing or 

matching is determined by program offices and recorded in the program’s 

Grant Funding Slate (see the section Grant Funding Slate - New Grants), 

then examined by the slate memorandum reviewing offices during clearance, 

and is ultimately approved or disapproved by the Secretary as a component 

of the program’s Grant Funding Slate.

a. When a waiver occurs soon after the first-year award, and it will not be

addressed in the program’s NCC Grant Funding Slate, program offices will 

submit an “Amendment” to the original Grant Funding Slate addressing 

the waiver and will include the original slate (via an attachment) for the 

competition for full context.

b. If a POC has a large program that has numerous applicants requesting 

different waivers for different economic needs or circumstances, programs 

use a roll-up sentence in the Grant Funding Slate (e.g., “30 applicants are 
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requesting waivers...”), provide the reasons the waivers are being 

requested, and provide a justification for granting the waivers.

4. Waivers can be granted outside of a Grant Funding Slate, but the Grant 

Funding Slate must indicate whether waivers are granted before or after an 

award is made. See the Cost Sharing and Matching Contributions section in 

chapter 6 when waivers are granted after award.

5. Waiver approvals or disapprovals related to cost sharing or matching are 

recorded in box 10 of the GAN as a grant term and condition.

6. When an approved waiver results in a reduction to the required cost sharing 

or matching, the amount required of the grantee is reflected in box 10 of the

GAN.

7. When a waiver is disapproved, the required cost sharing or matching is 

recorded in box 10 of the GAN.

C. Guidance

1. In addition to including a GAN term and condition reflecting waiver approval 

and disapprovals, program offices may also issue letters of approval or 

disapprovals with the GAN.

2. Program offices may consult with their program attorney and OPEPD/GPO 

when considering approval or disapproval of waivers.

D. Other Pertinent Information – Reserved

4.10.3 Calculating Cost Sharing or Matching Amounts

A. Policy

1. Program offices calculate cost sharing or matching amounts as required by a 

program’s statute or regulation.

B. Procedures

1. Program offices in their review and calculation of cost sharing or matching 

amounts consider that:

a. For multi-year projects, cost sharing or matching amounts are calculated 

for each year of the project separately, entered in the grants management 

system, and included as part of the terms and conditions of the grant 

award. However, in the case of a grant program where matching is 

calculated for the entire project period, rather than for each year of the 

project, a grantee would not be out of compliance with its matching 
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obligation, even if it failed to meet the target for a particular year of the 

project if it met the matching requirement over the entire project period.

b. The estimated Federal funding amount can be used to calculate the 

matching amounts for the out-years of the project.

c. The application of cost sharing or matching to a Federal grant must be 

consistent with the applicant’s treatment of those costs to Federal and 

non- Federal projects alike. For example, if the applicant’s organization 

normally treats a cost for an activity as an indirect cost, that same cost

must not be treated as a direct cost for cost sharing or matching purposes. 

To determine if the cost sharing or matching proposed by the applicant is 

allowable, program offices apply the criteria and exceptions listed in 2 

C.F.R. § 200.306. 

2. Program offices specify on the GAN, for any grant award that includes cost 

sharing or matching, the level or percentage of matching funds the applicant 

is required to contribute to the grant.

C. Guidance

1. The applicant cost sharing or matching amounts required by a program’s 

statute or regulation are generally calculated in one of two ways. The 

applicant is either required to share a percentage of the total cost of the 

program or is required to match a percentage of the amount of the Federal 

share. Depending on the program’s requirements, the following formulas may 

be used to calculate the applicant’s share:

a. Percentage of the total costs of the project:

Federal recommended amount x Applicant’s share (%) of the total cost of 

the project / Federal share (%) of the total cost of the project = Applicant 

matching amount

Example: The applicant’s cost sharing or matching requirement is 25 percent of 

the total cost of the project. The Federal share is 75 percent. The Federal 

recommended amount is $90,000.

($90,000 x 0.25) / 0.75 = $30,000

Adding the two amounts together (the $30,000 in the calculation and the $90,000 

Federal recommended amount), the total cost of the project is $120,000, of which 

the applicant must pay $30,000.

b. Percentage of the Federal amount:
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Federal recommended amount x Applicant’s share (%) of Federal 

recommended amount = Applicant’s matching amount

Example:

$90,000 x 0.25 = $22,500

Adding the two amounts together, the total cost of this project is $112,500, of 

which the applicant must pay $22,500.

D. Other Pertinent Information – Reserved

4.10.4 Pre-award Costs

A. Policy

1. Pre-award costs are expenses incurred for allowable purchases and activities 

before the funding period begins or in anticipation of an award, and where 

such costs are necessary for efficient and timely performance of the scope of 

work. Pre-award costs are authorized by EDGAR § 75.707(h), 2 C.F.R. § 

200.458, and by 48 C.F.R. for for-profit organizations.

2. Applicants and grantees may incur pre-award costs 90 calendar days before 

a new grant or NCC award without prior approval from ED in accordance with 

EDGAR § 75.263 and 2 C.F.R. § 200.308, unless prohibited by statute or 

regulation.

3. If an applicant or grantee wants to incur pre-award costs for allowable 

expenses more than 90 days before the beginning of a new project or budget 

period, 2 C.F.R. § 200.308(d)(1) requires the applicant or grantee to first 

obtain prior approval from ED before incurring the cost.

4. All costs incurred before ED makes the award are at the applicant’s or 

grantee’s risk. ED is under no obligation to reimburse such costs if for any 

reason the recipient does not receive an award or if the award is less than 

anticipated and inadequate to cover such costs (see also 2 C.F.R. § 200.458, 

“Pre-award costs”).

5. Program offices have the authority to disallow pre-award costs for justifiable 

reasons, even if the applicant or grantee wishes to incur them within 90 days 

before the beginning of the budget period (see the Procedures section that 

follows below).

B. Procedures

1. If an applicant or grantee informs program offices that they plan to incur preaward costs within the 90-day period, program offices inform the applicant or 
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grantee that they incur these costs at their own risk, and, if for some reason 

the applicant or grantee does not receive a grant or NCC award, ED will not 

reimburse the applicant or grantee for the costs.

2. When an applicant or grantee wants to incur pre-award costs more than 90 

days before the beginning of a new project or budget period, it submits a 

written request to ED that describes the reason for incurring the pre-award 

costs and the period during which the funds will be used. Program offices 

review the request and either deny or approve the request. If approved, 

program offices inform the applicant or grantee that the approval does not 

require ED to pay those costs if the applicant does not receive a grant under 

the competition or if the grantee did not receive an NCC award.

3. If, before the GAN is issued, program offices decide to approve the grantee’s 

request to incur pre-award costs more than 90 days before the start of the 

grant, program offices append Attachment 5 “Pre-Award Costs,” to the GAN 

at the time the GAN is issued. This attachment authorizes the grantee to 

spend grant funds in some or all budget cost categories, depending upon how 

the attachment has been completed by the program office.

4. If prior approval is granted after the initial GAN is issued, program offices 

generate a modified GAN, append Grant Attachment 5 to it, and issue it to the 

grantee.

5. If an applicant or grantee requests prior approval to incur pre-award costs 

before a GAN is planned to be issued, the program official, after reviewing the 

request, may approve the request in writing. In this case, Grant Attachment 5 

would not be used. The approval letter:

a. Informs the prospective grantee that it incurs pre-award costs at its own 

risk, and that the grant is not legally binding on ED until grant funds have 

been obligated and a GAN issued with the appropriate attachment;

b. States that ED is not obligated to pay for pre-award costs in the event the 

applicant or grantee does not receive a new or NCC award;

c. States that the grantee may not use pre-award cost authority to reimburse 

itself retroactively for cost overruns that a project incurred in a prior budget 

period of a multi-year award or in any other federally funded project; and

d. States that the applicant or grantee must use the pre-award cost authority 

in a manner consistent with the approved scope and objectives of the 

funded project.

6. When program offices disallow pre-award costs, even if an applicant or 

grantee wishes to incur them within 90 days before the beginning of the 

budget period (e.g., pre-award costs are not allowable, allocable, or 
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reasonable under the grant program or grant project), program offices prohibit 

the grantee from exercising its authority to incur pre-award costs by 

appending Grant Attachment 15, “Prior Approval Requirements,” and 

checking the appropriate box to deny pre-award costs. Additionally, program 

offices may disallow pre-award costs in writing.

C. Guidance

1. Examples of legitimate pre-award costs in a grant project may include:

a. Engaging a consultant, consistent with Federal and organizational conflict 

of interest and consulting/contracting rules, to do work directly related to 

the project’s success, which must be carried out before its start;

b. Buying equipment before the grant start date to receive a concessionary 

price from a vendor; and

c. Traveling for ED-sponsored conferences that occur before the start of the

project period (e.g., Pre-application workshops).

D. Other Pertinent Information 

1. For informational purposes only all GAN attachments can be found at 

GAN Attachments for Discretionary Grants

4.10.5 Program Income

A. Policy

1. Program income is defined as funds that grantees generate directly from a 

project activity or earn because of having been awarded a grant. Generating 

program income under a grant to defray program costs, where appropriate, is 

authorized by 2 C.F.R. § 200.307. 

2. ED policy allows grantees to exercise any combination of the options 

specified in 2 C.F.R. § 200.307 accordingly:

a. Deducting from total allowable costs and third-party in-kind contributions 

the amount of program income generated in order to determine the level 

of Federal support allowed (this requires the grantee to remit program 

income back to ED);

b. Adding to funds committed to the project by the Secretary and recipient 

and used to further eligible project or program objectives; and

c. Using funds for cost sharing or matching purposes to finance the nonFederal share of the project or program.
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3. Grantees are not accountable to ED for program income earned after the end 

of a project period, unless the GAN includes a condition requiring 

accountability after Federal funding ends.

B. Procedures

1. Program offices include Attachment 6, “Request for Approval of Program 

Income,” as a standard attachment on all new and NCC award GANs, which 

permits grantees to exercise any of the options outlined in 2 C.F.R. § 

200.307. 

2. If program offices decide not to permit a grantee to exercise any one or all of 

the options outlined in 2 C.F.R. § 200.307, it must mark the option(s) as “Not 

Allowed” on Attachment 6 and include it with the hard-copy GAN. See the 

section Issuing Hard Copy GANs for New Awards. 

3. When program offices decide not to permit any one or all the options outlined 

in 2 C.F.R. § 200.307 for all grantees under an AL, they fill in the necessary 

information and include a statement that this Attachment 6 supersedes the 

standard Attachment 6, which is blank. Program offices then up-load this 

attachment into the grants management system. All grantees under the AL

will receive both the blank attachment and the completed attachment on the 

GAN package.

C. Guidance – Reserved

D. Other Pertinent Information

1. Although the following is not an exhaustive list, they are examples of 

circumstances for which program offices may decide to not permit a grantee 

to exercise any one or all of the options outlined in 2 C.F.R. § 200.307: 

a. When the grantee is a high-risk grantee.

b. When program offices determine, based on a justifiable reason (e.g., the 

nature of the grant program best supports the option of using program 

income to further the grant project’s goals and objectives), that it is 

appropriate to limit the options available to a grantee.

c. When the grantee is a for-profit grantee and program offices determine 

either that the use of program income would not be appropriate, or that the 

for-profit grantee should use a particular method due to its for-profit status.
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4.10.6 Indirect Costs – General

A. Policy

1. Indirect costs are incurred by a grantee for common objectives that cannot be 

readily and specifically identified with a particular grant project or other 

institutional activity without effort disproportionate to the results achieved. 

Examples include:

a. The costs of operating and maintaining facilities, equipment, and grounds 

(part of “facilities costs”);

b. Depreciation allowances (part of “facilities costs”); and

c. Salaries of administrators and services, such as payroll and personnel that 

benefit Federal programs (part of “administrative costs”).

2. Indirect costs are usually charged to the grant as a percentage of the 

allocation base, which can either be salaries and wages (e.g., when applying 

the ED Temporary Rate - see the Indirect Costs - Temporary Rates Plus 

Negotiated Agreements section), salaries and wages plus fringe benefits, or 

modified total direct costs (MTDC). This percentage is called the indirect cost 

rate and is obtained by dividing indirect costs by the allocation base of a 

grantee. The MTDC cost base is defined in 2 C.F.R. § 200.1. The MTDC 

base is adjusted for costs that do not require administrative effort or would 

distort the indirect cost rate.

3. In accordance with 2 C.F.R. § 200.1, MTDC consist of all direct salaries and 

wages, applicable fringe benefits, materials and supplies, services, travel, and 

subawards and contracts up to the first $25,000 of each subaward (i.e., 

subgrant or contract that meets the criteria for an assistance relationship 

under 2 C.F.R. § 200.331 even though the grantee designates it as a 

contract).

4. The Federal government’s policy on reimbursement of indirect costs is that 

Federal agencies pay their portion of allowable indirect costs that are 

allocable to their programs, as described in 2 C.F.R. § 200.414 and 

appendices III, IV, V, VI, and VII to 2 C.F.R. 200. 

5. Indirect costs are not reimbursed on construction grants, grants to individuals, 

or grants to organizations located outside the territorial limits of the United 

States, or for grants that exclusively support conferences.

6. Indirect costs are not reimbursed for fellowships and similar awards if the 

Federal assistance is exclusively in the form of fixed amounts, such as 

scholarships, stipend allowances, or the tuitions and fees of an institution.
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7. Indirect costs must not be charged to grants funded under programs with 

statutes or regulations that prohibit indirect costs.

8. Generally, to charge indirect cost to a grant, a grantee must have a current 

indirect cost rate agreement that is negotiated with and approved by the 

grantee’s cognizant agency, (i.e., the Federal department or agency providing 

the grantee with the most direct Federal funding subject to indirect cost 

support, or an agency that is otherwise designated by OMB).

a. If an applicant receives most of its Federal funding indirectly as a subrecipient via another entity (for example, an SEA), the conduit organization 

that provides the most pass-through Federal funding is responsible for 

establishing an indirect cost rate for the subrecipient.

b. If an organization receives a combination of direct Federal funding and 

pass- through funding as a subrecipient, and the entity does not have a 

rate established by some other cognizant agency, the Federal agency 

providing the most direct funding (or an agency otherwise designated by 

OMB) is the cognizant agency for cost negotiation.

9. Grantees with approved indirect cost rate agreements are permitted to charge 

indirect costs in accordance with their agreements, except under a grant 

subject to a restricted rate (e.g., supplement-not-supplant programs), a 

training rate program, or other programs where indirect costs are restricted or 

capped in statute or regulations, such as a cap on administrative costs (see 

the Administrative Cost Cap section).

10.Grantees with approved indirect cost rate agreements that are charging 

indirect costs to their grants based on the approved rate must not charge a 

cost to its grant as a direct cost if that cost is identified as an indirect cost in 

the grantee’s indirect cost rate agreement.

11.Direct cost allocation and indirect cost allocation are consistently treated 

across all Federal grants unless a provision of statute or regulation requires a 

different outcome.

12.When grantees do not have a federally recognized indirect cost rate 

agreement on the date ED awards its grant, and the grant programs are not 

subject to supplement-not-supplant requirements or training grant 

requirements, the grantees have the option of using either: 1) the temporary 

rate of 10 percent of budgeted direct salaries and wages (see the section 

Indirect Costs - Temporary Rates Plus Negotiated Agreements); or 2) the de 

minimis rate of 10 percent of MTDC, if the grantee is not a State, local 

government, or Indian Tribe that has received more than $35 million in direct 

Federal funding, (see the section Indirect Costs - De Minimis Rate - No 

Negotiation).
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13.Unless statutory or regulatory restrictions apply to indirect cost 

reimbursements, program offices cannot require grantees to accept an 

indirect cost rate that is lower than the federally negotiated indirect cost rate 

shown on their indirect cost rate agreement.

B. Procedures

1. Prior to award, during cost analysis, program offices review indirect cost 

information submitted by applicants in accordance with the section Reviewing 

Indirect Cost Information During Cost Analysis. 

C. Guidance – Reserved

D. Other Pertinent Information

1. The cognizant agencies for indirect costs for Institutions of Higher Education 

(IHEs) are the Department of Health and Human Services (HHS) or 

Department of Defense’s Office of Naval Research (DOD). See 2 C.F.R. part 

200, Appendix III, paragraph C.11.a.(1) . 

2. Administrative costs, both direct and indirect, are addressed in the section 

Administrative Cost Cap. 

3. The Indirect Cost Rate Decision Tree and Chart available at the link, 

Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process, defines the types of indirect cost information that may be 

included in applications and is a resource that program offices may use to 

assess the appropriateness of the indirect cost information submitted by 

applicants. 

3. The Indirect Cost Division SharePoint site includes information about indirect 

costs including an Indirect Cost FAQ Guide, indirect cost trainings, and 

grantees Cost Rate Agreements. 

4.10.7 Indirect Costs – When They Apply

A. Policy

1. Program officials permit grantees to apply the applicable indirect cost rates 

(e.g. restricted indirect cost rate or unrestricted indirect cost rates) that they 

are permitted to charge to their grants under the program for the period the 

rate is applicable to a Federal award.

2. In accordance with 2 C.F.R. § 200.414(g), a grantee can request up to a fouryear extension of its negotiated indirect cost rate if it submits an extension 

request to its cognizant agency 60 days before the date the grantee would 

have to submit its rate proposal.
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3. Indirect costs are only recovered on the date a grantee submits an indirect 

cost proposal to its cognizant agency for approval, or on the start of the 

project period, whichever is later. Program officials do not increase the 

amount of a grant to cover increased indirect costs that were negotiated after 

the start of the budget period. However, with prior approval from program 

officials, grantees may increase indirect costs by shifting direct costs to 

indirect costs (see EDGAR § 75.560(d)(ii)(iii)). 

B. Procedures

1. Program offices, in accordance with 2 C.F.R. § 200.211(a)(15), include on the 

GAN the indirect cost rate that the grantee can charge to its grant, and the 

rate is applicable to the project period or budget period reflected on the GAN.

2. If a grantee that is not an IHE has a federally recognized indirect cost rate, 

and it re-negotiates a new rate with its cognizant agency before the end of its 

current budget period, ED will generally allow the grantee to apply the new 

rate to its grant. This new indirect cost rate should be applied according to the 

period specified in the indirect cost rate agreement, unless expressly limited 

under EDGAR or program regulations. Any grantee with an approved budget 

may amend the budget to account for a change in the indirect cost rate. 

However, any material changes to the budget which may impact the scope or 

objectives of the grant is discussed with the grant’s ED program contact (see 

EDGAR § 75.560 (d)(3)(ii)). ED automatically communicates this information 

to all grantees as a standard grant clause that appears on discretionary 

GANs.

3. If a grantee, that is not an IHE, seeks an increase in funding due to a newly 

negotiated rate increase, and the program deems it appropriate to increase 

funding because program funds are available to cover the increased grant 

amount resulting from the indirect cost rate change, program issues a 

supplement GAN reflecting an increase in funding.

4. Regarding IHEs, under 2 C.F.R. part 200, Appendix III, Indirect (F&A) Costs 

Identification and Assignment, and Rate Determination for Institutions of 

Higher Education (IHEs), ED must apply the negotiated indirect cost rate in 

effect on the date of the initial grant award to every budget period of the 

project, including all NCC grants awarded to the project. (See 2 C.F.R. part 

200, Appendix III, paragraph C.7.) Therefore, the GAN for each NCC grant 

will show the original indirect cost rate and it applies to the entire period of 

performance of the project. If the indirect cost rate agreement that is 

applicable to this grant does not extend to the end of the grant’s project 

period, the indirect cost rate set at the start of the project period must still be 

applied to the end of project period regardless of the fact that the rate has 

otherwise expired. ED automatically communicates this information to all 

grantees as a standard grant clause that appears on discretionary GANs.
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C. Guidance

1. Indirect cost rate agreements are usually established for periods coinciding 

with a grantee’s accounting (fiscal) year, not its grant award budget period or 

performance period. Consequently, a grantee might have to calculate the 

amount of indirect cost reimbursement to which it is entitled during a budget 

period by using two indirect cost rates.

D. Other Pertinent Information – Reserved

4.10.8 Reviewing Indirect Cost Information During Cost Analysis

A. Policy

1. Program offices review indirect cost information submitted by applicants when 

conducting cost analysis of the applicants’ Federal and non-Federal budgets.

B. Procedures

1. Program offices complete indirect cost information in the grant subprogram 

record to ensure that the correct indirect cost type is reflected in GAN block 

10.

2. When conducting costs analysis of an applicant’s indirect cost information, 

program offices review an applicant’s responses to the indirect cost questions 

on the U.S. Department of Education Budget Information Non-Construction 

Programs Form 524 Sections A, B and C (524 Budget Information Form) if 

the applicant is requesting indirect cost reimbursement on line item 10 of the 

form.

3. The grants management system will retrieve that indirect cost rate from the 

524 Budget Information Form completed by the applicant in Grants.gov and 

will populate the indirect cost rate into the Project Indirect Cost Rate data field 

on the Budget Category Details page. Program offices are responsible for 

entering applicant budget data into the Budget Category Details page and 

review, for accuracy, the indirect cost rate data submitted by the applicant on 

the ED 524 Budget Information Form, and the indirect cost rate populated into 

the Project Indirect Cost Rate data field.

4. The Project Indirect Cost Rate data field is modified by program offices when 

program offices deem it necessary to change the indirect cost rate based on 

its analysis of the indirect cost rate information submitted by the applicant 

(i.e., when supporting indirect cost rate information submitted by the applicant 

reflects that it has entered the wrong rate in Grants.gov, or when a rate has 

expired).
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5. The Project Indirect Cost Rate data field is filled in by program offices when 

the indirect cost rate is inadvertently missing on the ED 524 Budget 

Information Form submitted into Grants.gov, and program offices have 

determined that the applicant may charge indirect cost, or when an 

application and corresponding budget information (including indirect cost rate 

information) are not submitted through Grants.gov. 

6. When indirect cost rate information is missing from the ED 524 Budget 

Information Form, or other OMB approved program specific budget form, and 

program offices deem it appropriate to initiate a clarification contact with the 

applicant to determine if an indirect cost rate should be entered, program 

offices initiate the clarification contact in accordance with the section 

Clarification Contacts. 

7. When an indirect cost rate value is entered into the Project Indirect Cost Rate 

data field, program offices verify the rate in the grants management system, 

and it will automatically populate the indirect cost rate from the Project 

Indirect Cost Rate data field into Block 10 of the GAN.

8. Program offices responsible for entering and updating grant subprogram data 

must select “Yes” or “No” to indicate whether indirect cost is allowed under 

the grant program. If “Yes” is selected, program offices then select the 

Program Indirect Cost Type from one of the following choices: Restricted, 

Unrestricted, or Training. When one of these choices is selected, it will 

automatically populate in GAN block 10 from the grant subprogram record. If 

“No” is selected to reflect that indirect cost is not allowed, the Program 

Indirect Cost Type choices will be grayed out.

9. The program offices include the grant terms and conditions specified in GAN 

Attachment 4, “Limitations on Indirect Cost Recovery” if:

a. An applicant indicates on the budget form that it does not have a federally 

negotiated indirect cost rate agreement; or

b. The period covered for the rate in the rate agreement has expired or the 

applicant did not include a rate agreement in its application; or

c. The applicant has included indirect costs charged at its regular 

(unrestricted) rate, but the program requires a restricted rate.

10.If program offices are unsure about the reasonableness of the applicant’s 

requested indirect cost rate, or they have other questions about the 

applicant’s stated indirect cost rate or the base to which it is being applied, 

they are authorized to contact the applicant prior to award following the policy 

and guidance in the section Clarification Contacts. 
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C. Guidance – Reserved

D. Other Pertinent Information

1. Federal agencies will only engage in negotiations for an indirect cost rate 

agreement after a grant is awarded.

2. To aid program offices in assessing the appropriateness of the indirect cost 

information submitted by applicants, program offices may refer to the Indirect 

Cost Rate Decision Tree document available at: Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. The Types 

of Indirect Cost Rate table, also available at this link, is a resource that 

defines the types of indirect cost rates that applicants may include in their 

applications.

4.10.9 Indirect Costs – Temporary Rates Plus Negotiated 

Agreements

A. Policy

1. If a grantee opts to use the temporary indirect cost rate of 10 percent of 

budgeted salaries and wages, it submits an indirect cost rate proposal to its 

cognizant agency for indirect costs within 90 days after ED issues the GAN.

2. The grantee may continue to use the temporary rate after the 90-day period 

when its indirect cost rate proposal has been submitted to its cognizant 

agency within 90 days after ED issues the GAN.

3. The grantee must not charge its grant for indirect costs, if after the 90-day 

period, the grantee has not submitted an indirect cost proposal to its 

cognizant agency.

4. Under exceptional circumstances (e.g., natural disasters) per EDGAR § 

75.560(d)(2), program offices may allow a grantee to continue using the 

temporary indirect cost rate after the end of the 90-day period if the following 

conditions are met:

a. The grantee submits documentation explaining that exceptional 

circumstances inhibited submission of the proposal; and

b. The license holder determines that the submitted documentation

demonstrates that exceptional circumstances exist.
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B. Procedures

1. In most cases, ED will be the cognizant agency, and the ED Indirect Cost 

Group (ICG) will negotiate the rate for a grantee that does not have a 

currently approved indirect cost rate.

2. The Uniform Guidance, 2 C.F.R. part 200, Appendix VII.D.1.c, establishes the 

Department of the Interior (DOI) as the cognizant agency for all Federallyrecognized Indian tribal governments; thus, a tribal government that does not 

have an approved indirect cost rate will negotiate its indirect cost rate with 

DOI, even though the tribal government may only use the 10 percent 

temporary rate for its ED grant until it receives its negotiated rate from the 

cognizant agency.

3. Although unlikely, if an IHE applies for a grant and does not have an indirect 

cost rate, the IHE will negotiate its indirect cost rate with Department of 

Health and Human Services, which is the cognizant agency for virtually all 

IHEs that receive grants from ED, regardless of which Federal agency 

provides the IHE the most funding. (See 2 C.F.R. 200, Appendix III) 

C. Guidance

1. Exceptional circumstances may include natural disasters that interfere with a 

grant applicant or grantee’s ability to submit the required indirect cost rate 

proposal within the 90-day period. For information about verifying natural 

disasters, see the Guidance section in Extending Application Deadline Dates 

for Exceptional Circumstances. 

D. Other Pertinent Information

1. The 10 percent temporary rate calculated on budgeted salaries and wages is 

an ED established rate for use as an indirect cost rate on ED grants; thus, not 

all Federal agencies allow grantees the use of this rate.

4.10.10 Indirect Costs – Temporary Rates – Retroactive Recovery 

A. Policy

1. A grantee that opts to use the temporary rate, and that obtains a federally 

recognized indirect cost rate, may then use the federally recognized rate to 

retroactively claim indirect costs reimbursement. The recovery is subject to 

the following limitations:

a. The grantee may only recover indirect costs incurred on or after the date it 

submitted its indirect cost rate proposal to its cognizant agency, or at the 

start of the project period, whichever of the two occurs later.
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b. The total amount of funds recovered by the grantee under the federally 

recognized indirect cost rate is reduced by the amount of indirect costs 

previously recovered under the temporary indirect cost rate.

c. The grantee obtains prior approval from the Secretary to shift direct costs 

to indirect costs in order to recover indirect costs at a higher negotiated 

indirect cost rate.

d. The grantee may not request additional funds to recover indirect costs that 

it cannot recover by shifting direct costs to indirect costs.

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

4.10.11 Indirect Costs – De Minimis Rate – No Negotiation

A. Policy

1. Institutions of Higher Education (IHEs), federally-recognized Indian Tribes, 

State and Local Governments receiving less than $35 million in direct federal 

funding, and nonprofit organizations that do not have a current negotiated 

(including provisional) rate, and are not subject to the Department’s training 

rate or restricted rate (supplement-not-supplant provisions) may elect to 

charge a de minimis indirect cost rate of 10 percent of modified total direct 

costs (MTDC). This rate may be used indefinitely. See 2 C.F.R. § 200.414(f). 

2. State and local governments (including SEAs and LEAs), and Indian Tribes, 

must not use the 10 percent de minimis rate if receiving more than $35 million 

in direct funding, in accordance with 2 C.F.R. § 200.414(f); therefore, the ED 

ICD must be contacted for guidance if a State, local government, or Indian 

Tribe proposes to use the de minimis rate.

3. If an LEA that applies for a discretionary grant does not have an approved 

indirect cost rate and has not received a federally-funded grant before (e.g., a 

charter school LEA), the LEA, under ED’s procedures in EDGAR § 76.561(b), 

obtains a negotiated indirect cost rate from the SEA, its State.

4. A grantee that opts to use the de minimis rate must limit indirect cost 

reimbursement to 10 percent of Modified Total Direct Cost (MTDC). MTDC 

(see 2 C.F.R. § 200.1) consists of all direct salaries and wages, applicable 

fringe benefits, materials and supplies, services, travel, and subawards and 

subcontracts up to the first $25,000 of each subaward (i.e., a subgrant or 

contract that meets the criteria for an assistance relationship under 2 C.F.R. § 

200.331 even though the grantee designates it as a contract). 
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5. Grantees are not required to submit documentation, for ED review, justifying 

their use of the de minimis rate in accordance with 2 C.F.R. § 200.414(f). 

6. Grantees using the 10 percent de minimis rate must apply the rate to all of 

their Federal awards and may continue to use the rate indefinitely (until they 

decide to negotiate an agreement with their cognizant agency, which 

grantees may apply to do at any time). 

7. As described in §200.403(d), costs must be consistently charged as either 

indirect or direct costs, but may not be double charged or inconsistently 

charged as both.

8. Once a grantee obtains a federally recognized indirect cost rate that is 

applicable to its grant, the grantee may use that indirect cost rate to claim 

indirect cost reimbursement; however, the reimbursement is subject to the

following limitations:

a. The grantee may only recover indirect costs incurred on or after the date it 

submitted its indirect cost rate proposal to its cognizant agency, or at the 

start of the project period, whichever of the two occurs later.

b. The total amount of funds recovered by the grantee under the federally 

recognized indirect cost rate is reduced by the amount of indirect costs 

previously recovered under the temporary indirect cost rate, i.e., the de 

minimis rate. See (EDGAR 75.560(d)(3)(i)).

c. The grantee obtains prior approval from the Secretary to shift direct costs 

to indirect costs to recover indirect costs at a higher negotiated indirect 

cost rate.

d. The grantee may not request additional funds to recover indirect costs that 

it cannot recover by shifting direct costs to indirect costs.

B. Procedures – Reserved

C. Guidance—Reserved

D. Other Pertinent Information – Reserved

4.10.12 Indirect Costs – Training Grants

A. Policy

1. The policies for reimbursing indirect costs under training grants are as 

follows:
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a. If a government entity that receives a grant under a training grant program 

does not have an approved indirect cost rate and wants to recover indirect 

costs, it uses a temporary rate of 10 percent of budgeted direct salaries 

and wages (see the section Indirect Costs - Temporary Rates Plus 

Negotiated Agreements).

b. If a non-governmental entity receives a training grant, ED regulations limit

recovery of costs on training grants to the grantee’s actual indirect costs, 

as determined by its negotiated rate agreement, or 8 percent of a MTDC, 

whichever is lower (see EDGAR § 75.562(c)(1)). The 8 percent limit also 

applies to subawards under grants (see EDGAR § 75.562(c)(3)) if these 

subawards are for training as defined in EDGAR § 75.562(a). 

c. For purposes of calculating indirect costs for training grants, EDGAR § 

75.562(c)(2) defines a modified total direct cost base19 as total direct costs 

minus:

1) The amount of each subaward, including both subgrants and contracts 

that meets the criteria for an assistance relationship under 2 C.F.R. § 

200.330 even though the grantee designates it as a contract, which 

exceed $25,000;

2) Stipends, tuition, and related fees; and

3) Equipment, as defined in 2 C.F.R. § 200.33 as applicable. Indirect 

costs in excess of the training grant limit may not be charged directly, 

used to satisfy cost sharing or matching requirements, or be charged 

to another Federal award (see EDGAR § 75.562(c)(5)).

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

4.10.13 Indirect Costs – Restricted Rate Programs

A. Policy

1. The policies for reimbursing indirect costs under restricted rate grants are as 

follows:

a. Under ED discretionary grant program statutes that contain supplementnot- supplant provisions (restricted rate programs), grantees use a 

19 As stated in item c of this section, EDGAR § 75.562(c)(2) addresses exclusions specific to training 

awards. Other awards may have different exclusions, see 2 C.F.R. § 200.68. 
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restricted indirect cost rate when claiming indirect cost reimbursement 

(EDGAR § 75.563).

b. All grantees under supplement-not-supplant programs may only recover 

indirect costs at the restricted rate included on their negotiated indirect 

cost rate agreement.

c. Restricted rates for SEAs are included on the SEA’s negotiated indirect 

cost rate agreement. Restricted rates for LEAs are negotiated with the 

SEA, using a methodology described in the State’s indirect cost plan 

submitted under EDGAR § 75.561(b) and approved by the ED ICD.

d. Applicants for discretionary grants that are not a State or a local 

government and that do not have a negotiated restricted rate may use a 

temporary rate of 10 percent of budgeted direct salaries and wages until 

they negotiate a restricted rate.

e. Use of the temporary rate is subject to the provisions under the sections 

Indirect Costs – Temporary Rates Plus Negotiated Agreements and 

Indirect Costs – Temporary Rates – Retroactive Recovery of Indirect 

Costs. 

f. An applicant that is not a State or local government, and that already has 

a regular indirect cost rate, provides a copy of its rate agreement to ICD 

as the starting point for negotiating a restricted rate with the ICD.

g. If an applicant, other than a State or local government, does not want to 

negotiate a restricted rate agreement, the applicant has the option of 

charging indirect costs at 8 percent of the MTDC of its grant for the life of 

the grant in accordance with EDGAR § 76.564(c)(2),20 unless the ICD 

determines that the actual restricted indirect cost rate is lower than 8 

percent of MTDC. If the ICD determines that the actual restricted indirect 

cost rate is lower, the ICD requires that the lower rate be used in the 

applicant’s budget.

h. For grants under restricted rate programs, EDGAR § 76.569 requires that 

grantees multiply their restricted indirect cost rate by the “total direct costs 

of the grant minus capital outlays, subgrants, and other distorting or 

unallowable items as specified in the grantee’s indirect cost rate 

agreement.” This calculation is known as multiplying by a modified total 

direct cost base.

20 The 8 percent training grant rate under EDGAR § 75.562 should not be confused with the 8 percent rate 

under EDGAR § 75.564(d), which incorporates EDGAR § 76.564(c). The training rate must be used for all 

training grants made to non-governmental organizations. The 8 percent optional rate under EDGAR § 

76.564(c) can be used to avoid the expense to non-governmental grantees of calculating indirect costs. 
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B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information

1. Restricted indirect cost rates are lower than the regular (or unrestricted) 

indirect cost rates because the restricted rate excludes certain general 

management and fixed costs that would otherwise be included in the standard 

indirect cost rate calculation.

2. Program offices should refer grantees to EDGAR §§ 76.563 and 76.564–

76.569, and to the ICD’s cost allocation guide, for requirements and guidance 

in calculating restricted indirect cost rates.

3. The ICD’s Cost Allocation Guide for State and Local Governments is 

available at the Indirect Cost Division’s ED.gov webpage: So You Want to 

Know About Indirect Costs. 

4.10.14 Administrative Cost Cap

A. Policy

1. Administrative costs are grant expenses associated with the costs of 

administering the grant.

2. Some programs have statutory or regulatory caps on the amount of 

administrative expenses for the grant.

3. Programs that have an administrative cost cap include both direct and indirect 

administrative costs in the calculation of the cap.

4. For indirect costs— 

a. Applicants and grantees that have an indirect cost rate agreement that 

breaks out indirect facilities costs and indirect administrative costs 

separately only include indirect administrative costs towards the cap.

b. Applicants and grantees that have an indirect cost rate agreement that 

does not have a breakout of indirect facilities costs and indirect 

administrative costs include all indirect costs towards the cap.

5. Generally, an administrative cost cap also applies to any required program 

matching or cost sharing or matching funds (i.e., grantees cannot match to 

get around the cost cap).
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6. Programs that have an administrative cost cap explain to applicants and 

grantees how to appropriately budget using the cap.

B. Procedures – Reserved

C. Guidance

1. Generally, indirect administrative costs differ from direct administrative costs 

in that they are considered organization-wide costs and are therefore included 

in the negotiated indirect cost rate agreement.

2. Generally, indirect costs are not considered administrative if they are 

considered facility costs under an approved indirect cost rate agreement.

3. Direct administrative costs may include:

a. Overall program management, program coordination, and office 

management functions including the salaries and related costs;

b. Preparing program plans, budgets schedules, and related amendments;

c. Developing systems and procedures, including management information 

systems, for assuring compliance with program requirements;

d. Preparing reports and other documents related to the program 

requirements; and

e. Divisional level administrative services such as program specific 

accounting, auditing, or legal activities.

4. Certain direct costs—such as travel, the project director salary, and 

evaluation— may not necessarily all be administrative but may be direct 

program costs or may be partly direct program costs and partly direct 

administrative costs.

5. Program offices should consult with their program attorney with questions 

about administrative cost caps for their program.

D. Other Pertinent Information

1. Program offices may refer to two diagrams for additional information: 1) the 

first diagram details the different categories of administrative costs; and 2) the 

second diagram details the interaction between administrative cost caps, 

training rates, and the entities indirect cost rate agreement type. These 

diagrams are available at: Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process. 
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2. Program offices can access the links below for related resources:

a. ED’s Cost Allocation Guide for State and Local Governments located at 

the Indirect Cost Division’s ED.gov webpage So You Want to Know About 

Indirect Costs. 

b. 2 C.F.R. § 200.414 (describing facilities and administrative indirect costs).

c. OMB Uniform Guidance (2 C.F.R. Part 200) July 2017 FAQs. 

4.11 Protection of Human Subjects

A. Policy

1. If an applicant is planning research involving human subjects at any time 

during the project period, program offices review related information in the 

application to determine whether the research is exempt or not exempt from 

the protection of human subjects requirements in EDGAR Part 97. If program 

offices are unsure, the application is provided to the ED protection of human 

subjects coordinator to make the determination.

2. Nonexempt research cannot be conducted under a grant prior to the ED 

protection of human subjects coordinator’s human subjects research 

clearance. This usually includes a requirement that the grantee and any other 

entity “engaged” in the covered research have a Federal Wide Assurance 

(FWA) and Institutional Review Board (IRB) approval for the research.

B. Procedures

1. Program offices follow the guidance regarding exemptions addressed in 

Departmental Directive ACSD-OFO-035, “Protection of Human Subjects in 

Research: Extramural Research”, and in EDGAR § 97.104).

2. Program offices review the applicant’s response to ED’s Supplemental 

Information Form to the SF-424 (including item 3) against the application itself 

to assess the accuracy of the response and to determine whether proposed 

activities include covered research. This review occurs when grant 

applications are included in a funding slate. The ED protection of human 

subjects coordinator assists in this process, as needed.

3. Program offices, under no circumstance, accepts a change from “Yes” to “No” 

or from “not exempt” to “exempt” on the Supplemental Information Form to 

the SF- 424 from the grant’s project director. Only the authorized 

representative, or other appropriate institutional official of the applicant, can 

make a change of this nature.
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4. Program offices include the appropriate protection of human subjects grant 

award attachment with the GAN when a grant includes nonexempt research 

activities.

5. When in doubt as to whether an activity includes nonexempt research, 

program offices obtain a determination from the ED protection of human 

subjects coordinator regarding whether or not the study includes covered 

research.

6. Program offices should not delay the slate development and submission for 

approval process if the proposed research is not ready for IRB review. Under 

these circumstances, program offices consult with the ED protection of 

human subjects coordinator to determine if program offices should seek 

approval of the funding slate.

7. If it is decided that the funding slate should be submitted for approval, and 

approval is granted before the research is submitted for IRB review, program 

offices may obligate the grant awards; however, the appropriate HS grant 

award attachment must be included with the GANs. Since some grants 

include more than one research project, one or more of the following three HS 

grant award attachments may be included with the GAN:

a. HS 3 – is applicable to grants awarded before the grantee has complied 

with the pre-award requirements for assurances and/or IRB certifications. 

(If offices are unclear whether the project includes covered research, 

attachment HS3 must be included with the GAN.)

b. HS 2 – is applicable to grants with pending IRB reviews or indefinite 

activities.

c. HS 1 – is applicable to grants requiring continuing IRB review of covered 

studies.

8. For grants involving human subjects research that have not been cleared 

within 24 hours after obligation, program offices forward the application to the 

ED Protection of Human Subjects Coordinator (HS Coordinator) for review 

and human subjects clearance. The HS Coordinator reviews the application, 

obtains all the necessary assurances and/or certifications of IRB approval, 

and clears the project for human subjects research activities.

a. The IRB clearance process generally takes a minimum of 35 calendar 

days and varies depending on the grantee’s familiarity with IRB review, 

IRB review schedules, and the complexity of the research.

b. When the applicant has met all the necessary human subjects clearance 

requirements for award, the HS Coordinator will notify program offices in 
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writing and a copy of this human subjects clearance notice is kept in the 

official grant file.

9. Program offices follow-up regarding the human subject issue during the postaward conference. No covered research (which includes some evaluation 

research) can be conducted until the study has been granted clearance by 

the HS Coordinator, which involves obtaining assurances and IRB approval 

for the grantee and any other entity engaged in the research.

a. Close collaboration of program offices and the HS Coordinator is helpful in 

ensuring that the grantee provide all materials needed to complete ED 

protection of human subjects clearance in a timely manner.

10.An IRB can approve a nonexempt study that is not eligible for expedited IRB 

review for up to one year. If the research continues beyond the term of the 

initial IRB approval, program offices should ensure that the grantee obtains 

continuation IRB approval in a timely manner and provides that approval to 

the program office. Program offices include a copy of the IRB approval 

certification in the official grant file. After initial IRB approval that uses 

“expedited” review, no IRB continuation reviews are required, unless ED or 

the IRB determines otherwise.

11.If a study is a “clinical trial” as defined by the regulation, then the informed 

consent form(s) used for the study must be posted in a timely manner on a 

Federal website. “Clinical trial’ means a research study in which one or more 

human subjects are prospectively assigned to one or more interventions 

(which may include placebo or other control) to evaluate the effects of the 

interventions on biomedical or behavioral health-related outcomes. For each 

“clinical trial” as defined by the EDGAR Part 97 regulation, an IRB-approved 

informed consent form used to recruit study subjects must be posted on an 

ED-identified publicly available website when the study is closed to 

recruitment no later than 60 days after the last study participation by any 

subject as required by the study protocol.” Program offices contact the HS 

Coordinator for assistance with this procedure.

12.If program offices learn of serious or continuing noncompliance with the 

Common Rule (EDGAR Part 97) or of unanticipated risks in a study, that 

information is provided to the HS Coordinator in a timely manner to clarify the 

issue(s), and to identify corrective actions if applicable. This may include the 

HS Coordinator’s consultation with the study’s IRB. Under the regulation the 

IRB can require corrective actions. IRB- required corrective actions for 

serious noncompliance or unanticipated risks often include suspending or 

terminating the study or requiring that data collected while out of compliance 

can be used.
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C. Guidance

1. Most ED studies do not constitute “human subjects research” or fall under 

one or more of the Common Rule for the Protection of Human Subjects 

(EDGAR Part 97) exemptions. Some research activities are nonexempt.

2. If it is anticipated that a grant competition is likely to fund nonexempt 

human subjects research, program officials are urged to note this in the 

NIA so that the applicants’ proposed grant projects will address the human 

subjects requirements.

3. If an applicant is planning research involving human subjects at any time 

during the project period, the applicant checks “Yes” in item 3 of ED’s 

Supplemental Information Form to the SF-424. If the applicant checked 

“Yes,” the applicant needs to indicate in item 3 whether the research is 

exempt or not exempt from the protection of human subjects requirements 

in EDGAR Part 97. Where necessary, the program offices may contact the 

applicant for additional information or clarification after the Principal Officer 

(or his/her designee) has approved the funding slate.

4. Program offices do not need to forward an application to the HS

Coordinator if the applicant checked “No” (i.e., there are not any research 

activities involving human subjects) for item 3 of ED’s Supplemental 

Information Form to the SF-424, and the program offices agree with the 

applicant’s response. If program offices believe the applicant erred in 

checking “No,” or if it is unclear whether that is the case, program offices 

forward the application to the HS Coordinator for clearance.

5. Program offices are strongly encouraged to have all of the applicability of 

human subjects requirements addressed before obligating and awarding 

grants. Some applicants will have FWAs and IRB approval in place when 

applying; others will not be ready for IRB review (and ED human subjects 

clearance) for some time as they finalize study design.

D. Other Pertinent Information

1. The HS grant award attachments are available in the grants management 

system for use with GANs, and are also available for informational 

purposes at: Grant Attachments and Enclosures.

2. ACSD-OFO-035, “Protection of Human Subjects in Research: Extramural 

Research,” is available at the following link: Administrative Communication 

System (ACS) Directives.

3. Many research studies involve “cooperative research” with multiple entities 

that will be “engaged” in conducting the research. The regulation now 

requires that there be a single “IRB of record” for most covered studies. 
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Grantees are able to propose which IRB the research will be reviewed by, 

subject to ED approval. The compliance date for § 46.114(b) (cooperative 

research) of the 2018 Requirements is January 20, 2020.
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Chapter 5: Award Activities 

5.1 Introduction

The award phase of the discretionary grant process includes all activities for 

selecting and awarding new grants. The information presented in this chapter 

helps to ensure that ED awards its grants fairly and consistently across principal 

offices. Specifically, this chapter focuses on:

1. Funding recommendations;

2. Unique Entity Identification (UEI) registrations in SAM;

3. Qualifications needed to commit, obligate, and award grants;

4. Commitment, obligation and award functions;

5. Notifying unsuccessful and successful applicants;

6. The official grant file;

7. Transparency; and

8. Other awards.

5.2 Funding Recommendations

5.2.1 Developing Funding Recommendations

A. Policy

1. Program offices develop specific funding recommendations for those 

applications that fall within funding range (i.e., those applications which could 

be awarded a grant, given the amount of the program appropriation available 

once the applications are ranked from highest scored to lowest scored in 

accordance with competition review results).

2. EDGAR § 75.217(d) requires that the following be considered when 

developing specific funding recommendations for those applications that fall 

within the rank order list’s funding range:

a. The information in each application.

b. The rank ordering of the applications.

c. Any other information:
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1) Relevant to a criterion, priority, or other requirement that applies to the 

selection of applications for new grants;

2) Concerning the applicant’s performance and use of funds under a 

previous award under any ED program; and

3) Concerning the applicant’s failure under any ED program to submit a 

performance report, or its submission of a performance report of 

unacceptable quality.

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.2.2 Selecting Applications for Funding

A. Policy

1. The Principal Officer, in accordance with requirements in EDGAR, such as 

EDGAR § 75.217(d), is granted the authority to consider the information 

below in selecting applications for funding, including:

a. Selection criteria and any other requirements specified in the application 

notice, such as geographical distribution of awards;

b. An applicant’s use of funds and documented performance under a 

previous award under any ED program (see EDGAR § 75.217(d)(3)(ii)); 

c. Failure of the applicant under any ED program to submit performance 

reports or its submission of a performance report of unacceptable quality 

(see EDGAR § 75.217(d)(3)(iii));

d. An applicant’s receipt of funding from another organization within ED or 

another Federal agency to support identical or very similar project 

activities;

e. An applicant’s selection of key personnel whose total time committed to 

the project exceeds the amount of time that can be reasonably devoted to

other obligations and still meet the commitments of the grant21; 

21If the applicant is an IHE, ED staff must accept the institution’s written policy on full-time faculty time 

limits, if one exists. Otherwise, the program official should determine reasonable time limits and explain 

them in the official file. See 2 C.F.R. § 200.430. 
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f. The reviewers’ failure to consider information in the application related to 

the selection criteria (this is to be documented and justified with rationale 

provided for determining that the reviewers missed the information);

g. An applicant’s inclusion of unallowable project activities or costs that lead 

to a determination not to fund an application; and

h. An applicant’s inclusion of activities not authorized by statute, regulation,

or absolute priorities.

B. Procedures

1. If the Principal Officer concludes, after consultation with the program attorney, 

if needed, that the reviewers erred in scoring on a particular criterion, the 

Principal Officer documents: 1) the basis for determining that the reviewers 

erred in scoring before approving the final slate; and 2) why the discrepancy 

was not resolved during peer review.

a. The determination is filed in the competition file along with the approved 

slate.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.2.3 Grant Funding Slate - New Grants

A. Policy

1. Program offices submit the New Slate Memo Template recommending 

funding for new grants to the Grants Policy Office (GPO) in the Office of 

Planning, Evaluation and Policy Development (OPEPD/GPO).

2. OPEPD/GPO manages the clearance process for slates routing the cleared 

version of the slate through the Executive Secretariat to the Secretary for 

approval.

3. Program offices commit and record obligations for awarding new grants in 

accordance with their Funding Slates only after the Secretary has approved 

the Funding Slates.

B. Procedures

1. Program offices utilize the New Slate Memo Template and attachments, 

which provides specific guidance on how to complete a slate including 

pertinent grant award and funding information, and a recommendation for the 

Secretary’s approval.
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2. In the New Slate Memo Template, program offices include the information 

required for the approval of funding in accordance with the guidance and 

instructions provided in the New Slate Memo Template. 

C. Guidance – Reserved

D. Other Pertinent Information

1. The New Slate Memo Template is available at the following links: New Slate 

Memo Template. 

2. The NCC Slate Memo Template is also used to recommend funding for noncompeting continuations, supplements, and when funding down a previous 

slate. The sections of the Handbook that address non-competing 

continuations, supplements, and funding down the slate address the NCC 

Slate Memo Template, as applicable.

5.3 UEI Registration Reviews in SAM – Pre-Obligation

A. Policy

1. Program offices verify an applicant’s Unique Entity Identifier (UEI) in SAM to 

ensure its registration is active before recording an obligation and issuing an 

award.

a. If an applicant’s UEI verification in SAM determines an inactive 

registration, and there is not sufficient time for the applicant to complete 

registration before the Federal period of availability on the funds expires 

(typically 11:59:59 p.m. September 30), program offices use the SAM 

exempt functionality which allows a grant award to be made under 

extenuating circumstances, such as the need to make an award promptly 

to avoid funds lapsing.

B. Procedures

1. Program offices, when preparing an award, access SAM to ensure that an 

applicant’s UEI registration is active.

2. Program offices, if an applicant’s registration is inactive in SAM, immediately 

contact the applicant for resolution.

a. Program offices conduct this contact in accordance with the section 

Clarification Contacts, and their ATRP.

b. Program offices try to resolve registration issues with their applicants 

before the funding slate is approved, if not, program offices ensure the 
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UEI is active before making the award unless there is the need to make 

the award promptly to avoid funds lapsing.

3. If an applicant has been recommended and approved for funding, and it has 

an inactive SAM registration, and there is not enough time for the applicant to 

complete registration before the Federal period of availability on the funds 

expires (typically 11:59:59 p.m. September 30), program offices proceed with 

obligating the grant by selecting the SAM “Exempt” status and adding the 

following condition to the GAN:

“This grant is awarded under a Route Payment Flag because the grantee has 

not, as provided for in 2 C.F.R. Part 25, maintained an active registration in 

SAM, including an active Unique Entity Identifier (UEI). The Route Payment 

Flag may be removed once an “Active” UEI status is obtained in the SAM. If 

this concern is not addressed within thirty days, the Department may take 

additional action.” 

4. The grants management system automatically places a grantee on Route 

Payment when the SAM “Exempt” status is selected. This action routes a 

drawdown request to program offices for inquiry of the grantee’s status in 

SAM. Program offices approve a drawdown request once they are satisfied 

that the grantee has already acted or provided a timeframe to update their 

registration status in SAM.

5. Program offices proactively follow-up with grantees after award to ensure that 

their inactive registrations are expeditiously addressed. Inactive registrations 

are addressed within 30 days after award, but program offices seek to have 

this issue resolved by their grantees as soon as possible. Program offices 

consult with their program attorneys if it appears that a grantee may not 

resolve its inactive registration issue within 30 days for guidance about how 

best to proceed.

6. When a grantee’s registration status becomes active, the grants management 

system automatically removes the SAM Exempt Status, and program offices 

remove the Route Payment flag from the grant and issue an updated GAN 

without the “Inactive” SAM registration specific condition.

C. Guidance

1. Program officials, in extenuating circumstance (i.e., large numbers of awards 

to process during a short period of time) may seek a waiver from the Office of 

Business Support Systems (OBSS) Deputy Assistant Secretary to bypass the 

UEI verification process. 

a. If the waiver is granted, the program official receives a memorandum from 

OBSS that lists all the UEIs with active and inactive registrations in SAM 

that will be bypassed under the waiver.
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b. The program official will verify that the content of the memorandum is 

accurate by signing the memorandum and returning it to OBSS.

c. The returned memorandum signed by the program official authorizes 

OBSS to allow the grants management system bypass of the UEI 

verification process for the UEIs identified in the memorandum. Once the 

bypass has been established, OBSS will contact the program official to 

inform that the system bypass has been processed.

d. The approval of a bypass waiver does not absolve program offices from 

the responsibility of verifying in SAM active UEI registrations. Instead, it 

allows for this verification to occur without the grants management system 

involvement. Program offices are responsible for:

1) Verifying UEI registrations in SAM to ensure they are active and 

document the verification in the official grant file.

2) Granting a waiver does not transfer the responsibility to verify UEI 

registrations in SAM from the program offices to OBSS.

D. Other Pertinent Information

1. For requirements in regulations addressing SAM registrations, see 2 C.F.R. 

Part 25. 

5.4 Qualifications Needed to Commit, Obligate and Award Grants

5.4.1 General

A. Policy

1. The Principal Officer or his/her designee identifies different principal office 

staff to record commitments than the staff identified to record obligations and 

issue grants for a grant program.

2. The staff person designated to perform the commitment function must meet 

the minimum skill sets identified in the section Qualifications of Individuals 

Who Commit Funds. 

3. The staff person selected to perform the obligation and award functions must 

have a License to Obligate (license) from the director of GMPD and meet the 

skill sets in the section Qualifications of Individuals Who Record Obligations 

and Award Grants. 
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B. Procedures – Reserved

C. Guidance

1. The Principal Officer, or Executive Office staff, usually commit funds. 

However, the Principal Officer may choose to assign the commitment or 

obligation functions to qualified staff working directly with the grant programs, 

meaning supervisors, program officials, team leaders or program staff.

D. Other Pertinent Information – Reserved

5.4.2 Qualifications of Individuals Who Commit Funds

A. Policy

1. The staff selected to commit funds possess the following qualifications and 

skills:

a. Knowledge of ED’s budgeting process, including:

1) An understanding of appropriations law and the appropriation process;

2) An understanding of the theory and processing of funds allotments for 

each authorized program; and

3) An understanding of the process for transferring program funds from 

one principal office to another.

b. The ability to create and maintain records for each program and project 

code and present reports that:

1) Track fund commitments;

2) Track uncommitted balances; and

3) List funds to be allotted (indicating when they will be allotted).

c. Knowledge of ED’s grant award process, including:

1) The ability to identify where in the process funds are committed; and

2) An understanding of the roles and responsibilities of the ED personnel 

positions involved in making grant awards.

d. Knowledge of and the ability to use the grants management system

including:

1) The ability to use the financial management system;
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2) Familiarity with the various reports and report formats in the grants

management system and the finance system; and

3) An understanding of computer access and other security issues.

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.4.3 Qualifications of Individuals Who Record Obligations and Award 

Grants

A. Policy

1. Individuals who record obligations and award grants have the appropriate 

security clearance and appropriate access to the grants management system.

2. The staff selected to perform the responsibilities of a license holder are at the 

GS- 12 or higher grade, and possess the following qualifications and skills:

a. Knowledge of and the ability to apply the program statute, regulations, and 

requirements to grants they are authorized to award;

b. Knowledge of and the ability to apply the requirements of 2 C.F.R. Part 

200, EDGAR, Grants Policy Bulletins that have not yet been incorporated 

into this Handbook, and ACS Directives applicable to grants;

c. Knowledge of ED’s grant award process;

d. The ability to conduct a grant budget cost analysis;

e. The ability to communicate grant management and program policies and 

procedures to both internal and external customers;

f. The ability to explain any funding or administrative decision related to the 

grants they are authorized to award;

g. The ability to use ED’s grants management system; and

h. At least one year of experience with the program(s) under which they will 

record obligations and sign and award grants.

1) If the individual does not have the required one-year experience with 

the program, a waiver of this requirement, including a justification for 

the issuance of a license, is requested of GMPD. (Waivers with 
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justifications are sent to GMPD when new grant programs are 

established within the POC.)

3. License holders also meet the following training requirements:

a. Current license holders further their own professional development by 

identifying and participating in trainings and educational offerings to gain 

additional grant administration knowledge.

b. New license holders attend a GMPD orientation briefing, which includes a 

discussion of the license holders’ qualifications, responsibilities and 

essential roles related to the discretionary grants process.

c. All license holders attend an annual meeting sponsored by GMPD to

maintain their obligation authority. The purpose of this annual meeting is 

to:

1) Update the license holders on current grant-related information;

2) Review license holder requirements, as needed, to ensure consistency 

and integrity in the process;

3) Share best practices; and

4) Discuss any issues related to their responsibilities.

d. All license holders attend grants management system training that 

includes, but is not limited to, courses related to the discretionary award, 

post-award, and award closeout processes.

e. All license holders also successfully complete other required trainings, as 

they become available, to ensure that:

1) The POC is awarding grants in compliance with all applicable laws, 

regulations, and policies;

2) License holders are aware of POC best practices related to grants 

management, when sharing best practices is applicable, or the 

purpose of the training;

3) License holders gain an in-depth understanding of grants 

management;

4) License holders compile and maintain course materials and other 

resources on grants management; and
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5) ED receives information and feedback on its discretionary award 

process for continuous evaluation and improvement.

4. License holders have the authority, up to a specified dollar amount, to record 

obligations in the grants management system, and sign and issue new and 

continuation awards (GANs) for discretionary grants and cooperative 

agreements for specific AL programs.

5. License holders perform ED’s final review to ensure that the integrity of the 

discretionary grant process has not been compromised. The license holder’s 

signature on a GAN certifies that the grant award is made in accordance with 

all applicable rules, regulations, and ED policies. Accordingly, license holders 

are ED’s primary contact for addressing any legal requirements imposed on a 

grant, whether by statute, regulation or in terms and conditions of the award; 

however, inquiries from the media are referred to the OCO, and responses 

are handled in accordance with instructions from OCO.

B. Procedures

1. The director of GMPD issues a license to an individual (License Holder) 

selected by the POC to record obligations and issue awards (see the section 

Requesting a License to Obligate Funds).

C. Guidance

1. Program offices are encouraged to participate in GMPD policy forums for 

information about updates or changes to 2 C.F.R. Part 200, and EDGAR, as 

well as other pertinent information related to grant award and administration 

topics. 

D. Other Pertinent Information – Reserved

5.4.4 Requesting a License to Obligate Funds

A. Policy

1. Requests for a License to Obligate Funds (license) are submitted for review 

and approval to GMPD in a timely manner, so that program grant funds may 

be obligated without unnecessary delays.

2. Once a license is issued, it remains in place unless it is revoked, cancelled or 

updated in accordance with the policies and procedures addressed in the 

section Maintaining and Updating a License. 
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B. Procedures

1. The Principal Officer or his/her designee (such as executive office staff) 

provides the Discretionary Grants License Holders Request Form and a 

memorandum to the director of GMPD to request a license. The 

memorandum:

a. Lists the nominees;

b. Confirms that the Education Central Automated Processing Systems 

(EDCAPS) Production System – User Access Request Form has been 

completed and submitted for everyone; and

c. Lists any nominees for which a waiver is sought of the requirement that 

nominees have at least one year of experience working with a program, 

and for which the Discretionary Grants License Holders Request Forms 

are included with the waiver section completed.

2. GMPD issues a license based on the information provided by the Principal 

Officer. The license identifies the AL program numbers and the monetary 

amount of the individual’s obligation authority.

3. GMPD forwards the license to the Principal Officer or his/her designee who 

forwards the license to the selected staff.

4. The license holder retains, and makes available upon request, the approved 

license.

C. Guidance

1. The Principal Officer should identify at least one person in their principal office 

to have a license with obligation authority to cover the maximum obligation 

amount for any grant issued by the principal office.

D. Other Pertinent Information

1. The Discretionary Grants License Holders Request Form can be found at 

the following ConnectED link: Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process. 

5.4.5 Maintaining and Updating the License

A. Policy

1. Program offices, at least annually, review licenses and notify GMPD of any 

changes needed due to administrative changes such as name changes, 
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adding or deleting ALs, changes in obligation amounts, and corrections to 

ALs that may have been inadvertently left off the original license.

2. License holders, to maintain their obligation authority, complete and submit a 

financial disclosure form on an annual basis.

B. Procedures

1. Program offices timely submit requests to update licenses to GMPD to ensure 

that grants are obligated without unnecessary delays.

2. After the end of the fiscal year (September 30), GMPD provides each 

Principal Officer a list of current license holders. The list contains the 

name(s), ALs, and authorized obligation amounts.

3. Principal Officers, using the list of current license holders provided annually 

by GMPD, review the list to determine if the information is still accurate, 

whether changes to individual licenses are needed, or if licenses should be 

revoked or cancelled (see the section Revoking or Cancelling a License to 

Obligate Funds).

4. The Principal Officer or his/her designee certifies to GMPD that the license 

holders who remain on the list have met all applicable training requirements 

established by GMPD, including attending the annual briefing for license 

holders.

5. To update a license, the Principal Officer or his/her designee (such as the 

Executive Office staff) submit the Discretionary Grant License Holder Request 

Form stating:

a. The name of the individual, and the changes needed to update the 

license.

b. GMPD, after review and approval, will issue the updated license, and 

forward it to the Principal Officer or his/her designee to distribute the 

updated license to the license holder.

C. Guidance – Reserved

D. Other Pertinent Information 

1. The Discretionary Grants License Holders Request Form can be found at the 

following ConnectED link: Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process
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5.4.6 Revoking or Canceling a License to Obligate Funds

A. Policy

1. ED commits the license holder to a high personal level of responsibility and 

accountability for Federal funds. The license holder’s authority to obligate ED 

funds and to make certain administrative changes to approved projects on 

behalf of ED is not absolute and may be revoked or canceled upon written 

request by a Principal Officer to GMPD, or by GMPD.

2. GMPD revokes the authority to obligate if the license holder conducts any of 

the following activities (Note: The list below is not all-inclusive. Any use of the 

license that indicates a lack of proper stewardship and or professionalism on 

the part of the licensee is grounds for revoking a license):

a. Misuses the authority to obligate funds and award grants by:

1) Making awards that exceed the authorized obligation amount of the 

license or making awards not covered by the license; or

2) Making cumulative awards that exceed the limits of a program 

appropriation or fund allotment;

b. Violates ED’s computer security requirements by sharing a user ID or 

allowing an unauthorized user access to secured screens;

c. Misrepresents ED deliberately on matters of grants regulations or policy;

d. Otherwise demonstrates inability or unwillingness to comply with grant 

management requirements, including program statutes, GEPA/DEOA, 2 

C.F.R. Part 200, EDGAR, this Handbook, and all other directives related 

to ED’s grant making functions; and/or

e. Does not meet the training requirements to maintain his/her license.

3. GMPD cancels a license for non-punitive reasons such as:

a. A license holder ends his/her employment at ED;

b. The individual is no longer with the principal office that requested the 

issuance of the license;

c. The individual’s authorized obligation amounts and programs have 

changed (in these instances a new license may be issued);

d. The individual is no longer performing the duties of a license holder; 

and/or
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e. The principal office requests the cancellation for other non-punitive 

reasons.

B. Procedures

1. When a Principal Officer wishes to revoke or cancel a license for due cause 

(see the Policy section above), the Principal Officer submits a written request 

to GMPD identifying the license holder, the license holder’s obligation 

amount, and the ALs that the license holder is authorized to obligate.

2. Upon receipt and review of a Principal Officer’s request to revoke or cancel a 

license, GMPD will revoke or cancel the license. Once revoked or cancelled, 

the former license holder will no longer have obligation authority in the grants

management system.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.5 Commitment, Obligation and Award Functions

5.5.1 General

A. Policy

1. The following three key steps must be completed to award discretionary 

grants:

a. Recording the commitments for selected applications in the grants

management system;

b. Recording obligation of funds for selected applications in the grants

management system; and

c. Signing and issuing an official GAN.

2. Program staff selected to record commitments of funds for a discretionary 

grant program are prohibited from recording obligations of funds, and do not 

sign and issue grant awards for the same discretionary grant program.

a. Likewise, program staffs selected to record obligations of funds and sign 

and issue grant awards for a discretionary grant program must not record 

commitments of funds for the same discretionary grant program.

3. As a general matter, ED, to meet appropriation law requirements, 

communicates the awarding of a grant through a GAN.
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B. Procedures – Reserved

C. Guidance

1. Principal Officers, when selecting program staff to record commitments and 

obligations, should consider that the separation of the duties of recording 

commitments and obligations for the same grant program guards against any 

potential misuse of funds and reduces the possibility of errors in awarding 

grants.

D. Other Pertinent Information

1. A commitment is an administrative “reserve” placed on funds to ensure their 

availability to make an award at the time an obligation is recorded.

2. An obligation of funds is made when a license holder signs and issues the 

GAN to an applicant notifying them of the specific award of funds under a 

grant competition. The recording of an obligation in the grants management 

system is required for the ED finance system to make payments of Federal 

funds to a grant recipient.

3. The GAN represents an obligation by ED, and reflects the project period, the 

current budget period, and the applicable grant terms and conditions.

5.5.2 Recording Commitments

A. Policy

1. Program staff selected to record commitments does so only after receiving 

the approved Funding Slate.

2. Funds are not committed for any application needing a clarification contact. 

These should be marked with an asterisk on the Funding Slate. Commitments 

for these applications are recorded only after the outstanding issues are 

resolved.

B. Procedures

1. Program staff that commit funds for a program verifies that the committed 

funding amounts between Oracle Financials (OF) and the grants

management system, using the Financial Management Support System 

(FMSS) Log for Transactions, are properly posted in OF for each grantee. 

Program staff also confirms that all funds for a given competition have been 

committed.

2. After reviewing the FMSS Log for Transactions and verifying that there are no 

issues with the information, the individual who committed the funds writes the 
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word “RECONCILED” on the report and signs and dates the report. The 

signed and dated report is then incorporated into the Grant Program 

Competition File as an official record of the completed task. In this way, 

program staff that commit funds confirm that all funds for a given competition 

have been committed.

3. Program staff records commitments in the grants management system by 

either individual PR/Award number or by a group of PR/Award numbers within 

an AL subprogram and schedule.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.5.3 Congressional Notification

A. Policy

1. Congressional notification, during which members of Congress are informed 

by the Office of Legislation and Congressional Affairs (OLCA) of any new 

grant awards made to the member’s constituents, takes place before the 

recipients of grant awards are officially notified and before ED notifies 

unsuccessful applicants.

2. Program offices wait two business days (starting on the next business day 

after the commitment date) before communicating funding decisions to 

applicants (either by issuing GANs or making direct contact with them) to

allow time for congressional notification to occur.

3. Program offices cannot start the two-business-day waiting period, if the 

abstracts, slate, and other documents required for congressional notification 

are not available in the grants management system. The waiting period 

begins when OLCA has received all the required documents.

4. OLCA proceeds with congressional notification once it has either:

a. A customized abstract for each project application being funded; or

b. A copy of the generic abstract for all grants under a program.

c. Abstracts must be submitted in accordance with the abstract requirements 

set forth in the ED Abstract Form instructions available at, Grant 

Application and Other Forms and program offices may request the 

submission of revised abstracts to address inconsistencies as appropriate. 

See section Post-Award Conference. 
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B. Procedures

1. OLCA, to ensure the timely completion of the congressional notification 

process, accesses the grants management system daily and searches, using 

date ranges, for committed slates. OLCA then assembles congressional 

notification packages that contain the purpose of the program, abstracts 

(generic or individual), and other documents, as applicable.

2. OLCA will not conduct notification for projects for which program offices have 

not made commitments in the grants management system.

3. When paper applications are submitted, program offices forward a copy of the 

slate along with copies of all project abstracts to OLCA. Program offices 

provide the abstracts to OLCA for all applications selected for funding under 

the program, including those for which funds have not been committed due to 

clarification contacts.

4. OLCA will notify program offices of any problems with the timely completion of 

the congressional notification process. In such cases, program offices confirm 

with OLCA that the congressional notification process has been completed 

before notifying applicants of their funding status.

C. Guidance

1. Program offices are strongly urged to make timely awards, and as early as 

possible allowing time for congressional notification to occur. If exigent 

circumstances cause delays in recording commitments and obligations for 

issuing awards, and the delays could result in funds lapsing, OLCA may 

determine to waive or shorten the two business days for congressional 

notification.

D. Other Pertinent Information – Reserved

5.5.4 License Holder Review Prior to Obligations and Issuing New 

Awards

A. Policy

1. License holders ensure that all related and pertinent information is accurate 

and complete before recording obligations and issuing GANs for new awards.

a. The licensed individual that records the obligation of funds for an award is 

also the same person that signs and issues the GAN.
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B. Procedures

1. The license holder reviews the following materials and the award information 

on the GAN for accuracy and completion before recording an obligation and 

issuing a grant award:

a. Documentation that a cost analysis of the applicant’s budget was done to 

ensure that all budget items are allowable (for all years of a multi-year 

project);

b. Documentation that unallowed activities, if any, were identified and 

removed from the project and budget;

c. Documentation of any requested clarification calls; and

d. The GAN with required attachments and enclosures (both standard or 

program specific) available in the grants management system. 

1) Grant Attachments and Enclosures that appear with the blue asterisk 

(*) on ConnectED print with every GAN issued by ED, since these 

grant attachments and enclosures are standard for all ED grants. The

grants management system is programmed for these grant 

attachments and enclosures to print automatically with GANs. 

2) Grant attachments and enclosures without the blue asterisk are not 

standard to all ED grants and will not automatically print when GANs 

are printed. However, these attachments are available in the grants 

management system for selection by program staff when programs 

deem that they are applicable to a grant.

3) Program offices, in consultation with their program attorney, develop 

program-specific grant attachments for all awards under a grant 

program, if necessary. Program offices upload the program-specific 

attachment in the grants management system. 

b) Program-specific attachments are developed and uploaded in the 

grants management system to print on all GANs under an AL and 

not for an individual grant award.

2. Program offices add a specific clause or term and condition in the grants 

management system to appear in box 10 of a single GAN. In this instance, a 

term or condition is added to address a grant’s specific requirement, mitigate 

a risk, or address an issue concerning a high-risk grant.

a. Program offices consult with their program attorney regarding the content 

of any specific clause or specific term and condition before issuing it with a 

GAN. See the section Enforcement. 
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b. Program office include information regarding terms and conditions in the 

approved Grant Funding Slate.

3. License holders, in addition to reviewing GANs to ensure that all applicable 

GAN attachments are included and that any specific conditions imposed on 

the grantee, including those associated with high-risk designations, are also 

included, they also review to ensure that the following, if applicable, are 

included prior to officially notifying a successful applicant of its grant:

a. Any cost sharing or matching requirements, whether mandatory or 

voluntarily committed.

b. The program indirect cost rate type and the project indirect cost rate along 

with the standard indirect cost condition.

c. Other pertinent information including the correct recipient’s name, award 

amount and contact information.

d. If applicable, Grant Attachment 7, “Budget and Project Activity 

Recommendations/Changes,” which officially informs grantee and 

incorporates into the grant any budgetary changes and/or specific cost 

items that have been reduced or deleted from the budget as a result of the 

budget cost analysis.

C. Guidance

1. Program offices are encouraged to use and sign the Funding 

Recommendation Checklist or other similar checklist available to program 

offices, to demonstrate that a cost analysis was performed, and that all the 

requirements listed under the Procedures section were addressed.

D. Other Pertinent Information

1. The Funding Recommendation Checklist is available at the following link: 

Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process. 

2. The grants management system is the official repository for GAN attachments 

and enclosures. For information purposes only, the grant attachments and 

enclosures are also available on ConnectED at the following link: Grant 

Attachments and Enclosures. 
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5.5.5 Grant Award Terms and Conditions Related to FAPIIS

A. Policy

1. If, over the period of performance of a grant, the Federal share of an award 

will exceed $500,000, programs are required to inform grant recipients of the 

following requirements to report on matters related to their integrity and 

performance accordingly:

a. If the total value of a grantee’s active grants, cooperative agreements, and 

procurement contracts from all Federal sources exceeds $10,000,000 for 

any period of time during the period of performance of the ED grant, then 

the grantee must ensure information is reported to SAM (which is made 

available in FAPIIS) about civil, criminal, or administrative proceedings, 

and that the information remains current and up-to-date as described on 

the GAN Attachment 16, “Reporting of Matters Related to Recipient 

Integrity and Performance.” Specifically, the grantee reports information to 

FAPIIS semiannually about certain civil, criminal, and administrative 

proceedings that reached final disposition within the most recent five-year 

period and that related to the award or performance of a Federal award.

b. Grantees disclose, in writing to their ED program contacts, all violations of 

Federal criminal law involving fraud, bribery, and gratuity violations that 

could potentially affect an award from ED (see 2 C.F.R. § 200.113). 

2. Programs offices are required to inform grant recipients that all information 

posted in FAPIIS on or after April 15, 2011, except past performance reviews 

required for Federal procurement contracts, will be publicly available.

B. Procedures

1. The information listed under the Policy section that programs disclose to grant 

recipients is addressed in GAN Attachment 16. Program offices include this 

attachment with GANs, if, over a grant’s performance period, the Federal 

share of an award will exceed $500,000. 

C. Guidance – Reserved

D. Other Pertinent Information

1. The official version of GAN Attachment 16 is available in the grants 

management system. GAN Attachment 16 is also available for informational 

purposes only on ConnectED at the following link: Grant Attachments and 

Enclosures. 
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5.5.6 Electronic Signature for Grant Awards

A. Policy

1. License holders’ issue GANs using the electronic signature (e-signature) 

function.

B. Procedures

1. License holders ensure that congressional notification has occurred before 

using e-signature to record obligations and notify grantees.

2. License holders issue e-GANs unless an associated attachment or enclosure 

cannot be issued electronically, or there are justifiable reasons for not being 

able to use the e-signature function to issue GANs under a program (see the 

section Issuing Hard Copy GANs for New Awards).

a. To issue e-GANs, all associated specific terms and conditions and grant 

award attachments, including program-specific attachments, must be 

available in the grants management system. 

3. License holders review to ensure that all related and pertinent information is 

accurate and complete before using the e-signature functionality to record 

obligations and before issuing GANs for new awards by adhering to the 

Procedures in the section License Holder Review Requirements Prior to 

Recording Obligations and Issuing GANs for New Awards. 

4. License holders record obligations using the e-signature functionality, which 

automatically generates an email containing a link to the grants management 

system where the grant project directors and authorizing representatives view 

and print their GANs (electronically signed by the license holder) and their 

associated attachments.

5. Project directors and certifying representatives are registered in the grants 

management system to access the Adobe Acrobat version of the GANs, 

which includes all applicable grant attachments, enclosures, and specific 

terms and conditions.

a. Program offices refer project directors and certifying representatives that 

need assistance with registering in ED’s grants management system to 

the system Hotline.
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C. Guidance – Reserved

D. Other Pertinent Information

1. An e-GAN cannot be issued if any of the following attachments are required 

unless the content of these GAN attachments is included within box 10 of the 

GANs on a case-by-case basis as a specific condition. If not addressed on 

case-by-case basis as a specific condition in box 10 of the GAN, the data 

fields contained within these attachments must be completed by hand and the 

attachments along with the associated GAN must be issued in hard copy. See 

the section: Issuing Hard Copy GANs for New Awards. 

a. Grant Attachments 5 “Pre-Award Costs”.

b. Grant Attachment 7 “Budget and Project Activity 

Recommendations/Changes”.

c. Grant Attachment 15 “Prior Approval Requirements”.

d. Copies of these Grant Attachments are available for information purposes 

at the following ConnectED link: Grant Attachments and Enclosures. 

5.5.7 Requirements for Awarding a Grant

A. Policy

1. Generally, to comply with appropriations law, ED:

a. Records the obligations, and

b. Issues the GAN by 11:59:59 PM EST to make the award on September 30 

or the last date on which funds are available for obligation.

2. Electronic GANs issued using e-signature that are not delivered electronically 

on or before September 30 are presumptively not valid. The affected grant 

funds may lapse and would be returned to the U.S. Department of Treasury.

3. Hard-copy GANs that are not delivered to the U.S. Postal Service or other 

commercial carrier by midnight September 30 are presumptively not valid.

4. Simply recording an obligation of funds in the grants management system for 

a grant does not meet the legal requirements for awarding a grant. Legal 

requirements for awarding a grant are as follows:

a. There is documented action to establish a firm commitment on the part of 

ED;
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b. The commitment to award a grant is unconditional22 on the part of ED;

c. There is documented evidence of the commitment to award the grant; and

d. The commitment is made during the period the funds are available for 

obligation by ED.

B. Procedures – Reserved

C. Guidance – Reserved

D. Other Pertinent Information

1. Additional information about appropriations is available at the following link: 

Principles of Federal Appropriation Law, Vol II at 7-32-3(1991). 

5.6 Notifying Applicants

5.6.1 Notifying Successful Applicants

A. Policy

1. The GAN generally serves as ED’s official notification to grant applicants 

informing them that their applications have been selected for funding. It is 

ED’s official record of award, and it provides specific details about the grant, 

including the amount of the award, specific terms and conditions, and 

pertinent contact information.

2. The GAN includes standard attachments addressing payment procedures; 

performance and financial reporting requirements; audit requirements; 

program income; and any other required information that the grantee needs to 

know. It also includes any applicable program specific attachments.

3. The GAN informs grantees when their projects are being funded at a level 

less than the applicant’s requested amount.

B. Procedures

1. Program offices prepare GANs with the required information, and appropriate 

standard clauses and attachments, and the license holder signs and issues 

the GAN (see 2 C.F.R § 200.211 and the section, Recording Obligations and 

Issuing GANs for New Awards).

22 As used in appropriations, “unconditional” relates to any acts the applicants must complete before 

funding is secured; it does not limit ED’s ability to attach conditions to an award that must be followed 

during the grant.
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C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.6.2 Notifying Unsuccessful Applicants

A. Policy

1. Program offices formally notify unsuccessful applicants that their applications 

were not selected for funding.

B. Procedures

1. Program offices notify unsuccessful applicants in writing and specify why the 

application was not selected for funding. The notifications also include the 

applicant’s rank order and reviewer comments with the reviewers’ names 

deleted.

2. Program offices do not provide unsuccessful applicants with additional 

substantive feedback concerning a competition, unless the applicant requests 

an explanation under EDGAR § 75.218 (b). 

3. Unless statutes or program regulations provide otherwise, program offices 

notify unsuccessful applicants at the same time successful applicants are 

notified, after the two-business-day Congressional notification period.

Unsuccessful applicants are not notified earlier without approval of OLCA.

4. Program offices that intend to notify unsuccessful applicants before 

successful applicants have been notified submit a written waiver request to 

OLCA stating their rationale for early notification.

C. Guidance

1. Notifications from program officials to unsuccessful applicants may be form 

letters issued to all applicants under the program, or they may be customized 

letters issued to each applicant. These letters may be generated in the grants 

management system. 

D. Other Pertinent Information

1. The records of unsuccessful applicants are temporary and are maintained in 

accordance with ED’s record schedule for “Grant Administration and 

Management Files” (ED Schedule No. 254). This record schedule indicates 

that unsuccessful applications are destroyed/deleted 3 years after rejection or 

withdrawal. The ConnectED site, Information Management contains a link to 

the General Records Schedule available at: General Records Schedules. 
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2. The Records and Management Division establishes ED’s record schedules 

with the approval of The National Archives and Records Administration 

(NARA).

3. A record schedule is the document that provides legal authority for the final 

disposition, including destruction, of the records in an office, component, or 

agency.

5.6.3 Appeals by Unsuccessful Applicants

A. Policy

1. Unless an administrative appeals process is provided in a program statute23, 

ED does not provide a right of administrative review for applicants who have 

unsuccessfully competed for discretionary grants. Therefore, generally grant 

applicants cannot administratively appeal ED’s decision not to select their 

application for funding.

2. ED may reconsider an unsuccessful application if the applicant notifies ED of 

substantive problems related to the review of its application or provides proof 

that its application was mishandled.

a. A substantive problem related to the actual review may exist, for example, 

when a reviewer entered scores for the wrong applicant on the form, 

resulting in an incorrect overall score. However, an applicant disagreeing 

with a reviewer’s scores or comments, absence evidence of actual 

reviewer bias, does not meet the standard of what constitutes a 

substantive problem.

B. Procedures

1. To reconsider an unsuccessful application in accordance with Policy item 2, 

the program offices review the situation and consult with the program attorney 

to determine if corrective action is needed. If the program office agrees that 

there are substantive problems related to the review of the application, and 

those problems resulted in the application not being funded, the program 

office, after consultation with the program attorney, may take the appropriate 

steps under the section Mishandled Applications for resolution.

23 As of the date of this Handbook, the only discretionary grant program managed by ED that, by statute, 

gives unsuccessful applicants a right of appeal is the Native American Career and Technical Education 

program authorized by Section 116 of the Carl D. Perkins Career and Technical Education Act of 2006, 

as amended by the Strengthening Career and Technical Education for the 21st Century Act. This right is 

granted under Section 116(b)(2) through a cross-reference to section 102 of the Indian SelfDetermination Act.
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C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.7 The Official Grant File

A. Policy

1. Program offices create, maintain, and dispose of an official grant file for each 

application awarded a grant, in compliance with Departmental Directive 

ACSD-OCIO-012, “Records and Information Management Program”; 44

U.S.C. Chapters 21, 29, 31, and 33; and 36 C.F.R. Chapter XII, Subchapter 

B, and applicable ED Comprehensive Records Retention and Disposition 

Schedules and National Archives and Records Administration (NARA) 

General Records Schedules (GRS).

2. Official grant files are maintained in either the grants management system or 

the Office 365 OneDrive.24 For official grant files maintained in the Office 365 

OneDrive, all documents generated by the grants management system are 

copied and uploaded to the Office 365 OneDrive file. Non-record Materials25

may be maintained in other locations.

3. Official grant files contain any of the following documents that are applicable 

to the grant program and the grant award for which the file is created26:

a. Application and related documentation from pre-award and award,

including:

1) Original approved application, plus any approved revisions (e.g., 

budget or approved application amendments);

2) The completed forms submitted by the applicant that are required by 

the competition application package;

3) Technical Review Forms with comments and scores;

4) Program-specific required documents; and

24 If a program official determines that a program office cannot use the grants management system to 

maintain the official grant files due to the reasons set forth, the program office’s records liaison officer, as 

the position is described in Directive OM 6:103, must, on an annual basis, inform, in writing, ED’s records 

officer of the determination and the exact location of their program office’s official grant files in the Office 

365 OneDrive.

25 U.S. Government-owned informational materials excluded from the legal definition of records. 26 Recorded information made or received by ED employees that is not required to be included in the 

official grant file, such as correspondence and certain documents, may still constitute a Federal “record,” 

as defined under 44 U.S.C. § 3301. This recorded information may require appropriate retention, as set 

forth in Directive OM: 06-103 and applicable law.
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5) Any risk information or other special circumstances of the grantee that 

were identified during pre-award review and that will be important for 

monitoring during project implementation;

b. Grant Awards, including:

1) Cooperative agreement, correspondence generated while drafting the 

agreement (see Guidance item 3), and any amendments to the original 

agreement;

2) Grant Award Notification(s) and any associated correspondence, such 

as that required for specific conditions and a high-risk designation;

c. Performance, financial management, and monitoring documentation 

during post award, including:

1) Any program-specific or award-specific documentation (e.g., project 

plans, evaluation reports, contracts, and agreements, if separate from 

the application and performance reports);

2) Annual, interim, and final performance reports, which include data for 

performance measures, and any internal assessment tools or notes of 

discussions of the reports;

3) Monitoring documentation, including reports (e.g., onsite monitoring 

reports), checklists, correspondence, including for specific conditions, 

and any other documents, such as relevant audits, required for 

thorough monitoring;

4) Technical assistance plans, corrective action plans, and enforcement 

actions;

5) Financial documentation (e.g., both original and revised budgets, any 

required grantee financial reports, and other financial documentation, 

as applicable);

6) Financial monitoring information such as large available balances, 

excessive drawdowns, and payment flags and resolution 

documentation, if applicable.

d. Administrative actions (including approved application amendments, 

supplemental awards, grant transfers, extensions of the final budget 

period);

e. Correspondence concerning the grant, either with the grantee or outside 

parties concerning the grant (see the Guidance section below for 

suggested criteria on what to include in the file);
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f. Any checklists used by staff (e.g., Funding Recommendation Checklist or 

Closeout Checklist);

g. Closeout documentation (e.g., correspondence, final performance and 

financial reports, and checklists); and

h. Any other documentation relevant to the grant throughout the life cycle 

(e.g., program-specific information).

4. Program officials ensure, through annual supervisory review (see the 

Procedures section below), that official grant files contain all required 

information and are maintained in either the grants management system or 

the Office 365 OneDrive.

5. All duties assigned to ED employees to implement the creation, maintenance, 

and disposal of an official grant file for each application awarded a grant are 

consistent with their respective position descriptions.

B. Procedures

1. Program offices manage grant files in accordance with the standard operating 

procedures in the Official Grant File Standard Operating Procedure (SOP) 

document available at Documents and Forms Referenced in the Handbook 

for the Discretionary Grant Process. The document identifies the 

responsibilities and deadlines for the official grant file, and it aligns with the 

official grant file policy. Maintenance of the official grant file is the 

responsibility of the assigned program staff as is addressed in this SOP.

2. Program offices, to ensure that official grant files are appropriately 

maintained, programs implement the responsibilities and deadlines for the 

following activities:

a. Creating the file;

b. Adding documents to the file;

c. Closing the file; and

d. Archiving the file.

3. For the annual supervisory review, to ensure that official grant files contain all 

required information and are appropriately stored, the program official, or 

his/her designee, review a randomly selected sample of official grant files in 

accordance with the following:

a. Conduct supervisory review using the Discretionary Grant Review Tool 

Template.
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b. The Discretionary Grant Review Tool Template should be revised, at the 

direction of the program official, based on the program-specific list of 

documents.

c. For an Assistance Listing (AL) number, 10 percent of active grants, not to 

exceed 100 grants, are randomly selected for supervisory review.

d. The randomly selected sample of files includes files assigned to all 

program staff working under an AL.

4. Program officials, for any official grant file identified as out of compliance with 

the requirements addressed in the Policy section, provides the assigned 

program staff a reasonable amount of time to bring the file into compliance. 

Considerations to determine a reasonable time include the amount of work 

needed to bring the file into compliance and the individual’s current workload.

5. Program offices, prior to destroying paper grant files converted to electronic 

formats, obtain authorization from ED’s Records Officer and their program 

attorney.

6. Program offices organize their official grant files in accordance with the 

document, “Organization of the Official Grant File document.”

C. Guidance

1. Program staff should maintain their official grant files in the grants

management system. ED’s grants management system is the preferred 

location because of limited document storage and because official grant file 

related processes are automated therein. If a program official determines that 

a program office cannot use the grants management system, due to system 

limitations, statutory data collection, reporting requirements, or other specific 

programmatic factors, then the program office’s programs maintain their 

official grant files in the Office 365 OneDrive.

2. To foster increased electronic record retention, paper grant files should be 

converted contemporaneously with electronic files, and in accordance with 

applicable law, to electronic formats for the grants management system and

Office 365 OneDrive storage.27

3. For correspondence and other documentation, program offices may consider 

the following when deciding what to file in the official grant file:

27If transitioning from one file site to another, program offices should minimize the transition time in order 

to avoid the file being maintained in two locations
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a. Will the item help program staff to recall previous conversations or clarify 

issues, decisions, and monitoring activities of the grant?

b. Will the item be important in ensuring that new program staff assigned to 

the grant understands the background of the grant, current status of the 

grant, and any outstanding issues that should be addressed?

c. Will the item serve as supporting documentation for providing technical 

assistance, requiring a corrective action plan, applying specific conditions 

or a high-risk designation, determining approval or denial of an 

administrative action, suspending or terminating a grant, or submitting a 

grant for suspension and debarment considerations?

d. Will the item need to be available upon request under the Freedom of 

Information Act (see the section Freedom of Information Act (FOIA) 

Request)?

4. Based on the results of the required annual supervisory reviews, as 

addressed in the Procedures section, the program official should consider 

whether compliance training on file maintenance is warranted for one or more 

program staff.

D. Other Pertinent Information

1. The grant file SOP, Discretionary Grant Review Tool Template, and the 

Organization of the Official Grant File document are available at: Documents 

and Forms Referenced in the Handbook for the Discretionary Grant Process. 

2. Departmental Directive ACSD-OCIO-012, “Records and Information 

Management Program

5.8 Transparency

5.8.1 Increasing Transparency of the Competitive Award Process

A. Policy

1. Program officials implement ED’s transparency standards to increase the 

transparency of discretionary grant application and award processes in 

accordance with goals found in ED’s Open Government Plan. 

2. Program Officials, to increase transparency beyond publishing NPPs, NFPs, 

and NIAs in the Federal Register, publish the following standard competitive 

award process materials, to the greatest extent practicable, on ED’s website:

a. Application package;
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b. Technical review forms from funded applications complete with score 

(names of reviewers should be redacted);

c. Application abstracts from funded applications (abstracts must be 

submitted in accordance with abstract requirements set forth in the ED 

Abstract Form instructions available at Grant Application and Other 

Forms, and program offices may request the submission of revised 

abstracts to address inconsistencies as appropriate (see section PostAward Conference) ;

d. Narratives from funded applications; and

e. List of funded applications (including first year awards during current fiscal 

year, when applicable).

B. Procedures

1. Program offices, in determining whether to disclose and publish competitive 

award process information for all or a sample of applications from a 

discretionary grant competition, take into account a number of considerations, 

including: 1) the total number of funded applications; 2) the size of application 

packages; and 3) the associated workload for each discretionary grant 

program competition.

a. If a sample of applications is disclosed, the ED website specifies that the 

applications represent only a sample along with the criteria that was used 

for selecting the sample.

2. To ensure that the disclosure and publication of competitive award process 

information meets the requirements of ED’s transparency goals, program 

offices: 

a. Work closely with both its program attorney and FOIA attorney in 

implementing ED’s transparency policy. Also, program offices consult 

Strategic Collections and Clearance (SCC), as needed, for specific 

guidance related to their responsibilities under the Privacy Act of 1974, as 

amended (5 U.S.C. § 552a) (Privacy Act), which may be accessed at the 

following link: Privacy Act of 1974. 

b. Include a transparency plan in the ATRP for each grant program 

competition that:

1) Describes a grant program’s efforts to increase transparency by listing 

materials the program office intends to make available to the public;

2) Describes how applicants and peer reviewers will be informed of their 

participation in the transparency efforts; and
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3) Describes the process to ensure that applicant and application 

reviewer proprietary and personally identifiable information will not be 

disclosed.

c. Inform potential applicants and peer reviewers about their participation in 

the ED transparency policy and do so by including their transparency plan 

in NIAs, application packages, and in peer reviewer training and materials.

3. Program offices, when disclosing and publishing a list of funded applications, 

organize the list by state, and include for each funded application:

a. The total award dollar amount for the initial year; and

b. The approximated amount for each subsequent year.

c. When disclosing or publishing this list the following standard disclaimer is 

included.

d. “Award amounts reflected in the application for subsequent years will be 

determined at the time continuation awards are made based on a number 

of factors and funding availability.” 

4. Program offices, when disclosing and publishing application narratives, 

consider whether such disclosures will negatively impact the integrity of future 

competitions due to plagiarism.

5. Program offices, within 90 days after grants are awarded, consider posting for 

public disclosure competitive award materials from a sample or all their 

funded applications on the ED website.

6. Program offices, to ensure materials are posted on the same Web pages for 

each grant program, post materials related to the grant application process 

(e.g., NIAs) on the “Applicant Info” Web page and those related to the award 

process (e.g., list of funded applicants) on the “Awards” Web page.

7. Program offices, before disclosed to the public, screen information as 

described in the “Redacting Personally Identifiable and Proprietary 

Information” section to ensure that proprietary and personally identifiable 

information is not disclosed.

a. The information is also to be electronically accessible to individuals with a 

range of disabilities, in accordance with established ED-wide policy 

located at the ED.gov site Accessibility Requirements for Electronic 

Documents. 
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C. Guidance

1. Program offices have the flexibility to provide a greater degree of 

transparency for grant program competitions by disclosing and publishing 

some or all the materials listed below:

a. Applicants’ intent to apply;

b. Applicants’ completed application package materials (including proposed 

budget, appendices) with information redacted to ensure that proprietary 

and personally identifiable information is not disclosed;

c. Peer reviewers’ completed technical review forms from unfunded 

applications (with reviewer names redacted);

d. Peer reviewers’ information (names, biographies, professional affiliations), 

without linking a specific reviewer to a specific application that was 

reviewed, since linking a specific reviewer with a specific application 

reviewed is unallowable;

e. Applications’ scores and rank order; and

f. Grant Award Notifications.

2. Program offices have discretion in determining which applications from any 

grant program competition should be disclosed to increase transparency. The 

disclosure of a few examples of funded application narratives or abstracts 

from funded applications is one way to increase transparency.

3. When developing a transparency plan for each grant competition (see item 2b 

in the Procedures section), program offices may use as a resource the 

“Transparency Plan Format” document available at the following link: 

Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process. 

4. Program offices are encouraged to collaborate with other program offices in 

their own POC and across ED to develop shared models and standards for 

increasing transparency of the grant application and award process, 

consistent with this Handbook.

D. Other Pertinent Information

1. In response to OMB’s Open Government Directive (OMB M-10-06), ED 

issued its Open Government Plan which established strategies for achieving 

the three principles that are the cornerstones of open government: 

transparency, participation, and collaboration. The plan is located at the ED 

website page Open Government Initiative at ED
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5.8.2 Redacting Personally Identifiable and Proprietary Information

A. Policy

1. Program offices are prohibited from disclosing personally identifiable or 

proprietary information contained in application narratives and technical 

review forms, and this information is redacted prior to disclosing and 

publishing application narratives and technical review forms.

B. Procedures

1. Program offices inform potential applicants of ED’s transparency policy, and 

of their option to redact confidential personal and business information by 

including in the NIA related required language from Chapter J of the 

Regulatory Quality Manual. 

2. In general, program offices redact all information identified by an applicant in 

its application narrative as proprietary. However, program offices work with 

applicants to ensure their good faith identification of proprietary information 

(see 34 C.F.R. § 5.11), and also work closely with their program attorney and 

the OGC FOIA attorney should they have specific questions regarding an 

applicant’s identification of information as proprietary.

3. Program offices, after announcing funding decisions and before posting 

application narratives, email grantees whose narratives are going to be 

posted on ED’s website and give them a final opportunity to identify any 

proprietary information in their proposals. Any information identified by 

grantees in response to this email is redacted from their application narrative 

before it is posted.

a. Program offices use the document, “Draft E-Mail Requesting Grantees to 

Identify Proprietary Information in Applications ED Intends to Make Public” 

to prepare the email. The document is available at: Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. 

4. Program offices review the application narrative and technical review forms to

ensure that all personally identifiable information is identified and redacted.

C. Guidance – Reserved

D. Other Pertinent Information - Reserved
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5.9 Issuing Hard Copy GANs for New Awards

A. Policy

1. License holders’ issue hard copy GANs when:

a. Program-specific attachments and enclosures are not available in the

grants management system and cannot be uploaded into the system by 

the program office.

1) Program-specific grant attachments and enclosures may not be 

uploaded in the grants management system to print for an individual 

grant award and may only be uploaded in the system to print for all 

grant awards under a specific grant program.

b. GANs require attachments with data fields that are completed by hand 

outside of the grants management system (e.g., GAN Attachments: 5 

“Pre-Award Costs,” 6 “Request for Approval of Program Income”, 7 

“Budget and Project Activity Recommendations/Changes,” and 15 “Prior 

Approval Requirements”), unless the content of these GAN attachments 

are included within box 10 of the GANs on a case-by-case basis as a 

specific condition. If not addressed on a case-by-case basis as a specific 

condition in box 10 of the GAN, the data fields contained within these 

attachments must be completed by hand and the attachments along with 

the associated GAN must be issued in hard copy.; or

c. There are other justifiable reasons for not being able to issue e-GANs 

under a program (e.g., the grantee does not have internet service, or a 

program- specific attachment does not apply to all GANs under an AL, or 

there are system issues with the e-signature functionality).

2. License holders ensure that all related and pertinent information is accurate 

and complete before recording obligations and issuing hard copy GANs for 

new awards by adhering to the Procedures in the section License Holder 

Review Prior to Obligations and Issuing New Awards. 

B. Procedures

1. To issue a hard copy GAN, program offices override the set “Electronic 

Signature” default in the grants management system by choosing the “Hard 

Copy Signature” option. Selecting this option requires program offices to enter 

in the Comments box their reason/justification to issue hard copy GANs. A 

minimum of 20 characters is required to be entered in the Comments box.

2. When issuing hard copy GANs the license holder signs and dates three 

copies of the GAN immediately after recording the obligation. One copy of the 

original signed and dated GAN is given to the staff to be filed in the official 
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grant file; the second and third copies are mailed to the grantee’s authorized 

representative and project director.

3. For hard-copy GANs, the license holder, after the commitments are recorded, 

records the obligation of funds, signs, dates, and sends the GANs.

4. Obligations are recorded, the GAN is signed, and packages are prepared for 

mailing during the two-business day waiting period for Congressional 

notification. However, as indicated in the Congressional Notification section, 

the Congressional notification process is completed (including the two 

business day waiting period) before successful applicants are contacted and 

the grant packages mailed, unless OLCA approves an early contact.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

5.10 Cooperative Agreements – General

A. Policy

1. In accordance with the Federal Grant and Cooperative Agreement Act of 

1977 (31 U.S.C. chapter 63), Congress permits Federal agencies to choose 

the appropriate instrument to use in making awards. Program offices 

determine whether to use a cooperative agreement as the award instrument 

based on the nature of the relationship and the activities to be performed by 

the grantee.

2. Program offices use a cooperative agreement only when ED anticipates 

having substantial involvement with the grantee during the performance of the 

funded project (see the section Determining Substantial Involvement).

3. Program offices do not use cooperative agreements for the following 

purposes:

a. To increase ED’s involvement in projects beyond those authorized by 

statute;

b. To take away managerial control of a project from the recipient or to obtain 

stricter control over the administrative operations of its organization;

c. As a substitute for a procurement or contracting instrument to purchase 

goods or services for the benefit of the Federal government; or

d. For projects in which program offices will not have substantial involvement 

with the grantee during the period of the award.
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4. If a cooperative agreement is to be used, the agreement explicitly states the 

character and extent of the anticipated programmatic involvement of the 

program offices in the project and clearly defines the responsibilities of both 

parties in the agreement.

5. The agreement clearly conveys the programmatic benefits that the recipient 

would not otherwise have available to it in carrying out the project. Also, it 

must be developed carefully with the program attorney to avoid excessive ED 

involvement under the agreement.

6. Cooperative agreements are subject to the basic procedures and 

requirements established in EDGAR for application notice, application 

processing, technical review, program recommendation, award, and record 

retention established for grants.

B. Procedures

1. Program offices include on the GAN for cooperative agreements using one of 

the optional clauses in the grants management system designated for 

cooperative agreements.

2. Before obligating and issuing a cooperative agreement GAN, license holders 

ensure that the GAN contains the appropriate specific provisions and 

attachments, including a copy of the actual agreement.

3. If program offices do not have enough time to negotiate the terms of a 

cooperative agreement in time to make a timely award, program offices select 

the cooperative agreement GAN clause for inclusion on the GAN, which 

states that:

“The grantee will administer its grant under the terms of a cooperative 

agreement with ED, which is to be finalized by ED and the grantee. Once 

finalized, ED will attach the cooperative agreement to the GAN, and the 

cooperative agreement will apply retroactively to the grant start date and will 

remain in effect for the duration of the grant project. The terms of the 

cooperative agreement will reflect program requirements contained in the 

program’s statute and regulations. The grantee will carry out the project in 

accordance with all requirements as established in the cooperative 

agreement, and in accordance with its approved application.”

C. Guidance – Reserved

D. Other Pertinent Information – Reserved
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5.10.1 Determining Substantial Involvement

A. Policy

1. Program offices, prior to issuing a cooperative agreement, determine that the 

nature of the relationship between the grantee and ED, and the activities to 

be completed under the grant require substantial involvement on ED’s part.

a. Program offices consult with their program attorney when making this 

determination.

B. Procedures

1. When program offices determine, after advice and counsel from their program 

attorney, that a cooperative agreement is to be used, they ensure that:

a. The cooperative agreement clearly defines the responsibilities of ED and 

the grantee;

b. It includes the required items and information addressed previously under 

the General subsection; and

c. Each cooperative agreement is reviewed by the program attorney prior to 

signature.

C. Guidance

1. Federal statutes related to cooperative agreements neither define the phrase 

“substantial involvement” nor provide exact criteria for determining its 

presence in a project.

D. Other Pertinent Information – Reserved

5.10.2 Alternating Award Instruments

A. Policy

1. When program officials decide, after consulting with their program attorney, 

during the performance of a multi-year award, to convert a particular award 

from a grant to a cooperative agreement, or vice versa, the change can only 

occur at the time a continuation award is made, unless the grantee voluntarily 

consents to such a change at another time (EDGAR § 75.262).

B. Procedures

1. When the award instrument type is changed to a cooperative agreement, or 

from a cooperative agreement to a grant, the license holder ensures that the 
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applicable GANs and cooperative agreements include all required information 

as addressed in the section License Holder Review Prior to Obligations and 

Issuing New Awards. 

C. Guidance

1. Program offices assess the nature of the program, the individual project, 

and/or the ability of grant recipients to carry out their grant work.

a. Program offices may, during their assessments, consider the following 

examples prior to converting the award instrument type:

1) Some projects may start out as cooperative agreements in the first 

year and may be converted to grants after determining that the 

grantee’s ability to perform is better suited to an award instrument type; 

or

2) Other projects, initially funded as grants, may have to be continued for 

subsequent budget periods as cooperative agreements, if there is a 

need to revise the project or protect the Federal interest (such as when 

monitoring or reports indicate that substantially increasing ED’s 

programmatic involvement would benefit the work of the project).

2. ED programs that award Federal assistance as grants may decide to use 

cooperative agreements as the award instrument in future competitions, or 

vice versa, and may use the OMB Guidance on Determining Substantial 

Involvement at Documents and Forms Referenced in the Handbook for the 

Discretionary Grant Process. 

D. Other Pertinent Information – Reserved

5.11 Other Awards

5.11.1 Directed Awards (Earmarks)

A. Policy

1. If Congress mandates a directed/earmark award in a statute or appropriation 

law, the mandate identifies the specific recipient(s), the funding level of the 

award, and possibly the project activities the recipient is to conduct.

2. Despite the award being mandated by Congress, the recipient is required to 

submit an application (see EDGAR § 75.104(a)). However, since the award is 

mandated, the application from the recipient is not required to be reviewed in 

the same manner as that used for competitive applications.
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3. The requirements in 2 C.F.R. Part 200, EDGAR (that are applicable to 

discretionary grants other than those requiring grant competitions), and in the 

ED policies and practices that relate to those EDGAR requirements all apply 

to directed/earmark awards.

4. In cases where there is statutory authority for a directed/earmark award, but 

where there is no appropriation, ED is not required to fund the activity. 

Similarly, ED is not required to fund an entity in cases where there is no 

statutory authority, but Congress states its interest, in legislative history, that 

a particular entity should receive an award under a particular program. In 

these cases, programs offices consult with their Principal Officers, OLCA, 

OGC, Budget, and OPEPD/GPO.

B. Procedures

1. Program offices, before making a directed/earmark award, asks the recipient 

to submit an application that addresses the purpose for which the award is to 

be made. The application includes, at a minimum, a detailed description of 

the activities to be carried out and a detailed budget.28 The application also 

includes the required assurances and certification forms and any other 

required documentation before a grant award is made.

2. A directed/earmark grant application is not required to be peer reviewed; 

however, the program official, in all cases, will conduct a review of the 

application to:

a. Ensure that the award recipient describes the intended use of the funds 

with sufficient specificity to make certain that funds will in fact be used for 

the intended purposes;

b. Ensure that the budget costs are allowable;

c. Ensure that the applicant has the fiscal and administrative ability to 

implement the award and account for the funds; and

28 There must be statutory authority for the activity that the recipient proposes. For example: Congress 

specifically appropriates $1,000,000 for X program that ED awards to State University for rehabilitation 

assistance. State University proposes to build a swimming pool with the funds to help rehabilitate 

individuals. If the authorizing statute for X program does not authorize construction, ED could not make 

an award to build the swimming pool. State University would have to submit a different application to use 

the funds for some other non-construction project, or the funds would go to the Treasury. If Congress had 

been more specific in the appropriation and appropriated $1,000,000 for State University to build a 

swimming pool to be used for rehabilitation, the appropriation would have provided sufficient statutory 

authority to build a swimming pool.
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d. Determine the appropriate conditions to be included with the GAN, 

including conditions to assure proper administration of the grant and 

accounting for the funds.

3. Program offices include the standard attachments on GANs issued for all 

earmarked grants.

4. Program offices monitor and administer the award closely to ensure that the 

recipient completes the approved project activities described in the 

application.

C. Guidance

1. Program offices, at a minimum, review grant applications for 

directed/earmarks as addressed in item 2 of the Procedures section.

a. Program officials, if deemed appropriate, may decide to have the 

application reviewed by one or more ED staff that possesses, to the extent 

feasible, the expertise in the area(s) addressed in the application, or by 

external peer reviewers.

2. Unless otherwise dictated by statute or regulation, or by the scope of the 

project and its level of funding, directed awards usually have a one-year 

budget and performance period.

3. In cases where there is statutory authority for a directed or earmarked award, 

but where there is no appropriation, program officials may, if deemed 

appropriate, consider the application under a competition if the entity meets 

all the substantive and procedural requirements to have their application 

participate in a competition.

D. Other Pertinent Information – Reserved

5.11.2 Unsolicited Applications

A. Policy

1. ED policy strongly discourages the submission of unsolicited applications. 

The majority of ED’s discretionary grant funds are awarded through the 

competitive process. However, ED does have authority under EDGAR § 

75.222 to accept unsolicited applications if the applications meet certain 

standards.

2. Principal Officers and their staff are aware of the need to avoid circumstances 

where unsolicited applications—either in fact or appearance—are not solicited 

or pre-selected.
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3. Principal Officers consult with senior agency leadership and program attorney 

prior to initiating review of the unsolicited application.

B. Procedures

1. Principal Officers should take the following steps regarding unsolicited 

applications:

a. Establish a central receiving point in each POC for all unsolicited 

applications. Upon receipt of the unsolicited application, notify the 

applicant that the application has been received and describe the next 

steps appropriate for that application.

b. Consult with the program attorney to determine whether an unsolicited 

application should be considered for funding and if so, under which 

program it should be funded using the detailed procedures contained in 

EDGAR § 75.222. 

c. Review the unsolicited application by either of the following:

1) If the application could be funded under a current competition for which 

the deadline for submission of applications has not passed, the 

Principal Officer refers the application to the appropriate competition 

for consideration under the procedures found in EDGAR § 75.217. 

2) If the application could have been funded under a current fiscal year 

competition but the deadline has passed, the Principal Officer may 

consider funding the application only under exceptional circumstances. 

Exceptional circumstances are determined on a case-by-case basis. In 

most cases, the Principal Officer will not find exceptional 

circumstances and contacts their program attorney before making an 

“exceptional circumstances” decision.

3) If no competition has been planned or conducted under which the 

application could be funded, the application may be considered. If this 

is the case, the Principal Officer consults with the program attorney 

when determining if:

a) There is a substantial likelihood that the application is of 

exceptional quality and its project outcomes have national 

significance for a program administered by EDGAR § 75.222; 

b) The application meets the requirements of all applicable statutes 

and regulations that apply to the program; and

c) Selection of the project will not have an adverse impact on the 

funds available for other planned awards.
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d) A Principal Officer includes all documentation of pre-award contacts 

with the unsolicited applicant in the grant file.

e) Program offices enters the application’s information into the grants 

management system. 

C. Guidance

1. A Principal Officer, because unsolicited applications are not encouraged, may 

decide not to accept unsolicited applications under a grant program by 

publishing a notice in the Federal Register that it will not accept unsolicited 

applications under that program.

2. If the Principal Officer determines that the three factors in item 1© under the 

Procedures section appear to be satisfied, then the Principal Officer may use 

the template, “Documentation/Rationale for Unsolicited Application” that 

documents this determination and develops a memorandum for approval.

D. Other Pertinent Information

1. The template titled “Documentation/Rationale for Unsolicited Application” is 

available at the following link: Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process. 

5.11.3 Mishandled Applications

A. Policy

1. Program offices, under EDGAR §§ 75.219 and 75.221, may consider an 

application as mishandled due to administrative error if the application is:

a. Incorrectly assigned to the wrong grant program or priority within a grant 

program;

b. Addressed properly by the applicant but sent to the wrong address in ED;

c. Incorrectly determined to have been received late; or

d. Lost where the applicant can show proof the application was completed 

and submitted on time, and either:

1) The application was evaluated under the preceding competition of the 

program and the application rated high enough to deserve selection; or

2) The application was not evaluated under the preceding competition but 

would have rated high enough in the competition to deserve selection.
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B. Procedures

1. When a program official determines that an application was mishandled, the 

program official provides a written justification to the Principal Officer who 

may then approve funding of the mishandled application. If the mishandled 

application is discovered in time, it can be included in the appropriate 

competition.

2. If, however, the application is discovered too late to participate in the 

appropriate competition and there are no funds available in the current fiscal 

year appropriation, the application may be funded off the top of the next 

year’s appropriation if:

a. Program offices evaluate the application under the criteria for the 

competition; and

b. The application ranks high enough to be in the funding range for the 

competition.

3. If the application was not evaluated under the competition to which it was 

submitted, program offices assemble a panel to review the application to 

determine if it is in the funding range.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved
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Chapter 6: Post-Award Activities 

6.1 Introduction

The post-award process includes the activities necessary for POC staff to 

administer, monitor, make non-competing continuation awards, and close out 

awards made under ED grant programs. This chapter addresses a program office’s 

responsibilities to develop productive relationships with grantees, monitor its 

grantees for both performance and compliance, and provide TA to help grantees 

achieve project outcomes. Specifically, this chapter focuses on:

1. Post-award conference;

2. Monitoring;

3. Financial monitoring;

4. Risk reviews before NCCs;

5. NCC awards

6. Grant administration;

7. Data Collection extensions periods;

8. Time extensions; and

9. Grant closeout.

6.2 Post-Award Conference

A. Policy

1. Program offices conduct a post-award conference within 30 days of making 

the award and document it in the official grant file.

2. Program offices do not permit grantees to make changes to project scope or 

objectives during the conference or at any other time during the project period 

(see the section Prohibiting Changes to the Project Scope or Objectives of a 

Grant).

B. Procedures

1. Program offices conduct a post-award conference in person (e.g., during 

workshops, project director meetings, or other meetings), by telephone, or 

through web-based activities (e.g., videoconferencing or Skype) to confirm 
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and clarify the terms of the grant. The conference generally accomplishes the 

following, as applicable:

a. Establishes a mutual understanding of the expected performance 

outcomes, timelines, and milestones that were in the approved project 

application;

b. Establishes a mutual understanding of the measures for assessing the 

project’s progress and results that were in the approved project 

application;

c. Clarifies the frequency and method for monitoring and ongoing 

communication between ED and the grantee;

d. Addresses other TA (see the section Program Technical Assistance 

Plans) that ED will provide;

e. Reviews and clarifies specific regulatory, statutory, and financial 

management requirements affecting the grantee’s performance, as well 

as, financial administration and terms and conditions of the grant; 

f. Reviews and clarifies any project activity or budget issues or concerns 

(e.g., issues or concerns related to key personnel, indirect cost, cost 

sharing or matching, changes in project activities due to changes in 

requested amounts, and policies regarding carryover and no-cost 

extensions);

g. Reviews any deficiencies in the application identified during the peer 

review or pre-award process;

h. Reviews and clarifies required reports to be submitted (e.g. Annual 

Performance Reports, Federal Financial Reports, etc.), reporting due 

dates, and method of submission. Additionally, discusses specific 

websites (e.g., USASpending.gov, FSRS if applicable, SAM, etc.) that 

require grantees to establish a username and password for use during 

their period of performance;

i. Obtains additional grantee contacts who will assist in the administration of 

the grant, such as the person responsible for the drawdown of funds or 

other business contacts, because these contacts will be useful for 

addressing fiscal or other administrative issues. Program offices may 

enter these additional contacts into the grants management system since 

it can accept additional contact information even though the additional 

contacts will not print on the GAN;

j. Informs the grantee of the requirement in EDGAR § 75.620, which 

addresses the inclusion of a required disclaimer in any materials (e.g., 
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articles and editorials) that a grantee is going to produce with its grant 

(see the section Publications);

k. Reviews the Stevens Amendment statutory requirements addressed in 

GAN attachment 11, Specific Conditions for Disclosing Federal Funding in 

Public Announcements, with the grantee reiterating that they are required 

to disclose for their grant project the percent of the costs financed with 

Federal funds, the Federal dollar amount, and the percentage and dollar 

amount financed by nongovernmental funds when issuing statements, 

press releases, bid solicitations, and other documents describing their 

grant project. Also, remind grantee that they must document the equation 

used to determine the Federal and nongovernmental dollar amounts and 

percentages, and maintain this documentation with their grant file in the 

event ED requests to review their documentation.

l. Review all other GAN attachments and enclosures and convey that 

grantees must comply with the requirements established within each 

attachment and enclosure.

m. Informs the grantee of ED’s Open Licensing requirements, as it relates to 

item k, and to other grantee materials (see the section Open Licensing

Requirements); 

n. Addresses the importance of timely and thorough communication for any 

issues that arise during the project period, including but not limited to 

changes in key personnel, concerns with any component of the 

implementation of the grant such as beneficiaries served, and restrictions 

on changes to scope and objectives of the project;

o. Addresses the importance of regular drawdowns to meet immediate cash 

needs and that support the project’s activities;

p. Addresses the requirement to maintain active UEIs and SAM registrations 

for the grant’s entire performance period; 

q. Addresses inconsistencies between the submitted project abstract and the 

abstract requirements set forth in the ED Abstract Form instructions 

available at Grant Application and Other Forms. Program offices may 

request the submission of revised abstracts to address inconsistencies as 

appropriate. Program offices submit abstracts to OLCA for Congressional 

notification in accordance with section Congressional Notification, and 

they post funded application abstracts on ED.gov to foster increased 

transparency in accordance with section Increasing Transparency of the 

Competitive Award Process; and

r. Addresses other issues or concerns relevant to a project not covered by 

items listed above.
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2. While grantees may not make changes to project scope or objectives during 

the post-award conference discussion, program offices request revised 

budgets that reflect any reductions or other changes that program offices 

made to the budget before the grant award was issued, and these revised 

budgets are filed in the official grant file.

3. Program offices document the conference discussion, and any notes of 

actions taken or follow up needed in the official grant file in accordance with 

the Guidance recommended in the section The Official Grant File, and within 

the timeframe identified in that section.

4. A copy of the documented discussion addressed in item 3 is sent to the 

grantee for its file and future reference.

C. Guidance

1. The post-award conference generally is the first official contact between 

program offices and grantee personnel after receipt of the GAN. The 

conference begins program office’s productive relationship with the grantee 

and the monitoring process. This relationship is characterized by ongoing 

communication between the grantee and program offices throughout the life 

of the project.

2. The post-award conference should take place between program offices 

monitoring the grant and the grantee’s project director, financial or business 

office contact, or another authorized representative. Additional ED staff, and 

other grant staff, as deemed appropriate by the grantee, may be included as 

well.

3. When necessary, program offices will be able to obtain documentation and 

information from appropriate persons at the grantee organization regarding 

the grantee’s financial and records management systems, internal control 

processes, personnel policies that pertain to level of effort, travel, etc., or 

other appropriate documentation if the additional contact information is 

maintained as addressed above in Procedures item1(j).

D. Other Pertinent Information – Reserved
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6.3 Monitoring

6.3.1 Monitoring Introduction

1. Monitoring involves ED’s responsibility to assess grantees’ performance 

outcomes and ED’s fiduciary responsibility to hold grantees accountable for 

Federal funds through risk-based monitoring strategies that ensure that 

grantees have the capacity to manage grant funds consistent with Federal 

requirements. The goal of effective monitoring is to build evidence about 

effective approaches where possible, establish productive relationships with 

grantees that support results- oriented approaches to program management 

that when possible, demonstrate excellence, accountability, and successful 

performance outcomes. Effective monitoring also identifies potential or actual 

weaknesses and helps to find constructive ways to address those 

weaknesses.

2. Monitoring may be conducted informally and continuously as a preventative 

measure meant to minimize performance and financial management risks, or 

it may be more formal and intensive focused by carrying out related activities 

and interactions in accordance with established program monitoring plans 

(see the section Program Monitoring Plans). 

3. Monitoring may be exclusively virtual, without any on-site visits from program 

staff. Staff may conduct virtual visits and are responsible for documenting 

virtual monitoring efforts and data collected. 

6.3.2 General Requirements, Guidance, and Other Pertinent 

Information

A. Policy

1. Program offices monitor active discretionary grants with a focus on technical 

assistance (TA), continuous improvement, and attaining promised results and 

reliable performance and financial data.

2. Monitoring grantees continues until the grant is closed.

3. Program offices monitor grantees, to the extent appropriate, to ensure that 

grantees achieve expected results that are demonstrated by providing reliable 

data on their progress towards meeting project and performance measures, 

while also assuring compliance with grant requirements. Existing 

requirements in 2 C.F.R. Part 200, EDGAR, and in applicable program 

statutes and regulations extend equally to all grantees and their partners.

Specifically, program offices monitor to ensure that a grantee:
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a. Adheres to all applicable laws, regulations, conditions of the grant, 

certifications, and assurances (Compliance);

b. Manages Federal funds according to Federal cash management 

requirements, including expenditure of funds for authorized purposes 

(Fiscal Accountability);

c. Follows its approved application and any approved revisions (Program 

Management); and

d. Makes progress against established performance measures and project 

measures and provides reliable data that demonstrate the effectiveness 

and quality of the project (Performance).

B. Procedures – Reserved

C. Guidance

1. Program offices, in their monitoring efforts, use available data that are 

pertinent to the grants that will be monitored and synthesize those data to 

supplement what program offices may already know about their grantees, so 

that program offices may better understand their grantees’ level of 

compliance and performance. Data sources that may provide relevant data 

include performance and financial reports (e.g., the ED 524 Annual 

Performance Report, OMB cleared program specific performance and 

financial reports, the Federal Financial Report SF 425), data available in the

grants management system (e.g., large available balances, drawdown 

activities, payment flags), and program offices interactions with their grantees 

(e.g., in-person meetings, written and telephonic communications).

2. Program offices use the Post Award Monitoring (PAM) module as the primary 

monitoring tool. The module assists program offices with tracking monitoring 

activities.

3. Within the PAM module are tools for documenting and tracking monitoring 

activities. All the information in the grants management system can be 

accessed through the PAM module. PAM allows program offices to track and 

share grants with issues (e.g., any evidence of risk important enough to 

highlight or address in a specific condition or by other appropriate action), 

audit findings, corrective actions, missing documents, etc.

4. The PAM module includes a dropdown list of the most common grant issues 

that may occur on a grant. Program offices select a grant issue from the 

dropdown list, which is categorized as follows:
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a. Pre-award – Within this category, issues relating to grant applications, the 

awarding of new grants, and the awarding of NCC awards for existing ED 

grants may be selected.

b. Administrative – Within this category, issues relating to general grants 

management that are common to the administration of all grants may be 

selected.

c. Programmatic – Within this category, issues relating to programmatic 

progress and requirements may be selected.

d. Compliance – Within this category, issues related to compliance with 

statutes, regulations, policies, and grant terms and conditions may be 

selected.

e. Financial – Within this category, issues related to grant funds, the 

management and accounting of grant funds, grant transactions, and other 

fiscal matters applicable to the grantee may be selected.

f. Entity Status – Within this category, issues that fall within the overall 

status of an entity and its ability to receive and manage Federal funds may 

be selected.

g. Audit – Within this category, issues that are audit related may be 

selected.

h. Other – Within this category, issues that do not fall within the other seven 

categories are added. The category captures uncommon issues that will 

have to be described in a text box. Program offices document and record 

a grantee’s issue in PAM, and the information is available for other 

program offices across ED to review.

5. If other ED grants are associated with a UEI in PAM identified as having an 

issue, program offices responsible for those other grants may view the 

information available in PAM to determine if their grant has the same or a 

similar issue or the potential for that issue to occur. This determination may 

require program offices to conduct further inquiry, but these proactive efforts 

provide additional information to consider next steps, as appropriate.

6. When program offices use PAM grant issues functionality the grants 

management system homepage provides information related to the priority 

and severity of the issue. Program offices should have a program or POCwide plan for the best use of the grant issues functionality.

7. The PAM module also includes functionality that allows for the entering of 

project objectives and notable results. Generally, program offices determine, 

based on grantees performance goals and measures, what is extraordinary 
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and should be added to notable results and shared among the program’s 

team members or with other stakeholders. Similar to the grant issues 

functionality, program offices define and determine the best usage of the 

objectives and notable results functionality of PAM.

8. When program offices receive inquiries from other ED offices related to a 

grantee’s performance or compliance, the inquiries should be considered 

urgent and a timely response should be provided, so that awards, 

administrative actions or other performance and compliance matters are 

addressed quickly and appropriately.

D. Other Pertinent Information

1. Program offices may find the documents, “Categorization of PAM Issues,” 

which lists all common issue within a specific category, and “Post Award 

Monitoring (PAM) FAQs” which contains questions and answers vetted by the 

Functional Team in BSSD available at Documents and Forms Referenced in 

the Handbook for the Discretionary Grant Process. 

2. Training on the use of PAM is available, and training schedules can be 

accessed at EDCAPS Information.

6.3.3 Program Monitoring Plans

A. Policy

1. Principal Officers ensure that program monitoring plans are developed, 

maintained, and periodically evaluated to assess effectiveness and make 

improvements, as appropriate.

2. Program offices, in accordance with their program monitoring plans, identify 

grantees to be formally monitored (see section B below for details, and Policy 

item 2 of the section Monitoring Introduction), and share the list of grantees 

with the Principal Officer for review, approval, and tracking.

3. Program officials:

a. Ensure that monitoring data and results (available in Annual Performance 

Reports (APR) and other data sources) are used to improve grantee 

performance, financial management, enhance program requirements and 

purpose, and improve POC monitoring processes.

b. Share with program staff, OPEPD/GPO, and other ED staff offices grant 

program results and information gathered through monitoring about 

significant achievements including the best available research and 

practices that could serve as models for other projects, the Federal 

government, and the public.
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c. Report possible violations of Federal law or regulations to the cognizant 

officials, such as the Inspector General for financial misconduct or to the 

Assistant Secretary for Civil Rights for civil rights violations.

4. Program offices:

a. In accordance with the Program Monitoring Plan, develop the most 

appropriate form of monitoring for each grant, which may consist of site 

visits, desk and telephone reviews, reports, milestone evaluations, written 

communication, or other electronic methods including virtual monitoring.

b. Provide TA to grantees to improve performance.

c. Create detailed records of all monitoring activities (see the section The 

Official Grant File).

d. Provide grantees timely reports of monitoring activities that include:

1) Any findings and recommendations for changes and improvements to 

projects, as appropriate;

2) Corrective actions needed in instances of noncompliance; and

3) Identification of specific elements of exemplary performance, or best 

practices, in projects.

e. Report project-specific findings to other offices within ED, as appropriate.

f. Ensure that the appropriate disclaimer is included in project materials, as 

required by EDGAR § 75.620, if grant activities result in publications such 

as those described in the section Publications. 

g. Use the grants management system to monitor drawdown activity of each 

grantee.

B. Procedures

1. Program offices identify their grant programs to be monitored in the upcoming 

year, establish a schedule for monitoring, and identify needed resources for 

the Principal Officer’s review and approval.

2. Program offices prepare a Program Monitoring Plan in accordance with the 

following standards:

a. Standard 1: Program Monitoring Plans identify processes for ensuring 

that grantees are successfully achieving the goals and objectives of the 
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funded application and complying with financial and other statutory and 

regulatory requirements.

b. Program Monitoring Plans: 

1) Provide for sufficient and regular program performance and 

compliance monitoring of ED grantees to ensure compliance with grant 

requirements and to ensure that substantial progress is being made.

2) Serve as a guide for monitoring grants in each ED grant program 

office. 

c. Program Monitoring Plans include:

1) Risk-based procedures to target grantees with evidence of risk and 

high- risk grantees for monitoring and TA.

d. Risk-based procedures:

1) Identify specific indicators that measure the level of risk (i.e., does the 

indicator reveal evidence of risk or high risk?); and

2) Identify the level of risk, activities, and issues that would immediately 

flag a grantee for enhanced monitoring.

e. Description of the programmatic and financial management monitoring 

activities to be undertaken and the key actions to address poor performing 

grantees, including opportunities for TA.

f. Description of the monitoring activities to be undertaken to review contract 

and procurement administration for compliance with either a State or State 

agency’s (including an SEA) policies and procedures for procuring goods 

and services under a Federal grant, or for all other grantees, compliance 

with their own procurement procedures that comply with applicable State 

and local laws and regulations, and the Federal standards set forth in 2 

C.F.R. §§ 200.317 through 200.326. 

3. Standard 2: Program monitoring plans target monitoring efforts on those 

grantees identified as having evidence of poor programmatic and/or financial 

performance and compliance.

4. Standard 3: Program monitoring plans include programmatic and financial 

management monitoring protocols that facilitate transparency and information 

sharing with grantees.

a. Program monitoring protocols (i.e., any program monitoring instruments 

developed for assessing grantee information) that program offices use to 
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monitor their grantees are made available to grantees, so they know about 

the monitoring process, and criteria used to assess grantee performance 

and compliance.

5. The monitoring protocols developed in accordance with standard 3(a) are 

designed to:

a. Gather information that addresses the purposes of monitoring outlined in 

the section Monitoring – Introduction; 

b. Describe performance and assess the extent to which projects are 

meeting established program goals, objectives, and performance 

measures; and

c. Describe the scope, frequency, and methods of monitoring for each type 

of monitoring activity.

6. Program offices use the data collected, analyzed, and reported to:

a. Improve the principal office program monitoring and procedures;

b. Provide TA to grantees to improve performance;

c. Recommend revisions to ED leadership on program laws and regulations,

as well as guidance and policy to enhance program effectiveness;

d. Document best practices; and

e. Adjust program funding priorities.

7. Program offices report project-specific findings to other offices within ED, as

appropriate.

8. Program offices provide TA to grantees to improve performance (see the 

section Program Technical Assistance Plans).

9. Program offices ensure that the appropriate disclaimer is included in project 

materials, as required by EDGAR § 75.620, if grant activities result in 

publications such as those described in the Publications section. 

10.Program offices review their program monitoring plans annually and update 

them as appropriate.

11.Program offices create and store in the official grant file detailed records of all 

monitoring activities, contact with grantees (including email and telephone), 

and any information gathered (see the section The Official Grant File for the 

types of documents to be filed).
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C. Guidance

1. Program offices should consider the most appropriate form of monitoring for 

each individual grant, which may consist of site visits, desk and telephone 

reviews, reports, milestone evaluations, written communication, or electronic 

methods including virtual monitoring. Below are some factors for determining 

the appropriate form of monitoring:

a. Program-specific legal requirements for on-site monitoring; 

b. Funding levels;

c. Risk factors on the part of a grantee (including designation as a high-risk 

grantee);

d. Reported problems and grantee requests for assistance;

e. Availability of program office travel funds and ED program staff for on-site 

monitoring;

f. The need to review a grantee’s records or exchange documents;

g. The grant project’s level of significance, or importance, to the Federal 

government, ED, or to the field;

h. Geographic proximity of two or more grantees; and

i. Opportunity for monitoring multiple awards at the same grantee location, 

especially when on-site joint monitoring with other ED program staff is 

possible. 

2. Monitoring tools that are developed to assist program offices with their review 

of the data reported by grantees in their APRs are not required to be shared 

with grantees, since the APRs are OMB cleared data collections, and 

grantees are aware that program offices review these reports as a routine 

course of business during monitoring and to determine substantial progress 

prior to awarding NCC funding.

3. If monitoring tools require responses from ten or more entities, they generally 

require paperwork clearance according to the procedures established by 

OMB under 5 C.F.R. part 1320. Program offices consult with SCC for 

information about paperwork requirements. Even if ED has an approved 

information collection request requiring grantees to maintain certain 

information, if that information collection request does not provide for 

reporting to ED by a certain number of grantees every year, scripts used to 

monitor grantees or documents requesting information about performance 

must be approved unless they are directed to fewer than 10 grantees per 
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year. Program offices that use scripts as part of their monitoring process 

should work with SCC and their program attorney to ensure that information 

collection request requirements are met.

D. Other Pertinent Information

1. The document Program Monitoring Plans provides FAQs that program offices 

may consider as they develop their program monitoring plans. The document 

is available at the following link: Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process. 

2. SCC liaisons are available to help program offices determine if a monitoring 

protocol requires OMB approval.

3. Program offices may use the Risk Rubric Guide when monitoring. The Guide 

provides a framework that allows for flexibility across program offices to 

address specific issues, whether they be common risk concerns or statutory 

requirements, while also providing a consistent, methodical approach to 

evaluating risk levels within a given program. The Risk Rubric Guide is 

available at the following link: Documents and Forms Referenced in the 

Handbook for the Discretionary Grant Process. 

6.3.4 Program Technical Assistance Plans

A. Policy

1. Program offices provide Technical Assistance (TA) as needed, or in response 

to monitoring that is formally conducted in accordance with program 

monitoring plans (see the section Monitoring Introduction).

B. Procedures

1. Program offices provide TA to help a grantee understand, implement, 

evaluate, and improve their grant project, or develop an internal TA Plan (in 

response to monitoring that occurs in accordance with the Program 

Monitoring Plan) that is used as the basis for providing TA to the grantee.

2. TA, as addressed in Program offices TA Plans, is provided to a grantee or 

group of grantees to address an issue, or set of issues that have been 

identified through monitoring.

3. TA is provided for program-specific risks applicable to all grantees under the 

program and for program-specific risks applicable to a grantee accordingly:

a. TA is provided in a targeted manner to help a grantee understand and 

address one or more specific issues identified during monitoring; or
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b. TA is provided in an intensive manner to help a grantee address major, 

systemic issues identified during monitoring.

4. Program office TA Plans are submitted to the Principal Officers for review and 

approval.

C. Guidance

1. Program offices TA Plans may include the dissemination of useful 

programmatic and grants management information (i.e., information that is 

not necessarily risk or findings related) to a grantee or group of grantees.

2. Program offices have the discretion to issue TA Plans to grantees after

monitoring is conducted informally and continuously by following the Policy 

and Procedures in this section, or may for this type of monitoring, choose to 

inform their grantees of TA and provide that TA through alternative means 

deemed appropriate by the program offices.

D. Other Pertinent Information

1. The document titled, Program Technical Assistance Plans, provides FAQs 

that program offices may consider as they develop their Program TA Plans. 

The document is available at the following link: Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. 

6.3.5 Evaluating Risk during Monitoring

A. Policy

1. Program offices evaluate grantee risks during monitoring. Program offices 

determine if financial, programmatic, and administrative related risks exist, 

and decide if intervention (e.g., increased monitoring, requiring additional 

reporting, imposing specific conditions) is required.

B. Procedures

1. Program offices inform the program official if an identified risk is deemed to 

be serious or if a grantee is unresponsive to an intervention already imposed, 

or if the program official, in consultation with the program staff, will need to 

impose additional measures to bring the grantee into compliance, including, 

for example, imposing specific conditions to address the risk or designating 

the grant or grantee as high risk.

a. Programs offices consult with their program attorney before adding a 

specific condition, designating a grant or grantee as high risk, or taking 

any other enforcement action.
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2. Program offices document their risk evaluations in the official grant file.

C. Guidance

1. In addition to considering information and results from programmatic, 

performance, and fiscal data available in the grants management system and 

from other sources including reports required to be submitted by grantees 

(e.g., the ED 524B Annual Performance Report, the Federal Financial Report 

SF 425, OMB cleared program specific reports), program offices should 

consider data provided in the ERR when evaluating risk (see the section 

Evaluating Grant Applicant Risk Prior to Making New Grant Awards). 

2. “Examples of Risks Identified during Monitoring and ED Actions to Address 

These Risks.” This chart identifies some of the most common examples of 

grantee risks that require program offices intervention. The chart also 

identifies actions that program offices take, at a minimum, to address these 

common risks. The chart is not inclusive of all potential risks, and program 

offices may identify risks not captured in the chart that also may require 

intervention.
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At Risk ED Actions

Grantee had start-up 

difficulties, such as the 

delayed hiring of the 

project director or other 

key personnel.

Provide necessary TA on topics such as delays in activities, timeline adjustments, and 

budget adjustments, if any.

Establish a timeline for more frequent and ongoing contact with grantee to monitor 

progress.

At the appropriate time, plan and assist grantee for potential large carryover balance 

and/or possible no-cost extension at the end of the grant or consider reduction to 

NCC award.

Consider whether specific conditions or other actions may be appropriate.

An audit report is late, 

or grantee has failed 

to submit previous 

reports.

Inquire about the late or missing audit report and ask them to provide a copy of the 

report or an explanation. Establish a date for the grantee to submit the missing audit 

report and advise grantee that failure to submit the report may result in specific 

conditions or other actions (see the section Reviewing Audit Information 

During Monitoring). 

Refer to the document Guidance and Decision Tree on Risk Mitigation When 

Applicants are Missing Single Audits, to determine whether a specific condition or 

other action may be appropriate.

Inform the grantee that failure to submit reports is considered in NCC and new award 

decisions.

A report is late, or 

grantee has failed to 

submit previous reports.

Establish a date for the grantee to submit the missing report, and in the case of 

failure to submit the report, consider whether specific conditions or other actions 

may be appropriate.

Inform the grantee that failure to submit a report is considered in NCC and new award 

decisions.

The original budget 

contained many or large 

unallowable costs.

During the post-award conference, if not addressed prior to award, advise and 

provide grantee access with 2 C.F.R. 200, “Uniform, Administrative Requirements, 

Cost Principles, and Audit Requirements for Federal Awards” and other guidance.

Request an updated budget for the entire project period minus the unallowable costs.

Grantee has drawn down 

few or no funds.

Contact the grantee to confirm work is taking place under the grant and discuss 

ED’s policy on drawdowns.

Inquire about grantee’s payment pattern - Do they use their own funds and 

reimburse themselves, do they plan to drawdown funds quarterly, or do they have 

another rational for the infrequent drawdowns?

Provide TA and remind the grantee of ED’s 

drawdown policy. Monitor performance 

progress toward achieving grant goals.

Consider whether specific conditions or other actions may be appropriate.
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Grant has excessive 

drawdowns

Contact the grantee to explain ED’s policy on drawdowns and make sure the 

excessive drawdown gets resolved (see the section Excessive Drawdown).

Monitor grantee’s financial data in the grants management system often 

enough to review drawdown patterns and history.

Consider whether specific conditions or other actions may be appropriate.

Frequent turnover in grant

key personnel

Ensure key personnel replacements are qualified.

Contact the grantee to discuss why turnover is taking place including 

management concerns related to personnel.

Ensure new personnel are familiar with ED regulations and other governing 

regulations.

D. Other Pertinent Information

1. For information about imposing specific conditions, and the requirements for 

notifying a grantee, see the section Grant Performance – Addressing Risk 

and Other Issues. 

2. For information about designating a grantee high risk and the requirements 

for notifying a grantee of a high-risk designation see the section Grant 

Performance – Addressing Risk and Other Issues.

6.3.6 Reviewing Audit Information during Monitoring

A. Policy

1. Program offices review available audit information during monitoring to 

ensure that required audits have been conducted and submitted, and any 

finding and recommendations have been resolved or appropriately addressed 

by the grantee.

2. Single or program-specific audits are required for entities expending Federal 

assistance equal to or in excess of $750,000 during the entity’s fiscal year 

(see 2 C.F.R. § 200.501).

B. Procedures

1. Program offices review available audit information during monitoring by 

accessing audits at the Federal Audit Clearinghouse (FAC) database, through 

ED’s Audit Accountability and Results Tracking System (AARTS), reviewing 

audit information contained in ERRs, or accessing audit information using the 

Consolidated Substantial Progress Feed. 

2. Program offices contact grantees with missing required audits to inquire about 

the submission status of the missing audit report when the review of the audit 

data reveals that a grantee that is subject to the audit filing requirements of 2 
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C.F.R. 200 Subpart F, “Audit Requirements,” has failed to comply with the 

filing requirement. As necessary, program offices establish a deadline for the 

grantee to submit the report to the FAC.

a. Program offices review the decision tree and guidance document 

Guidance and Decision Tree on Risk Mitigation When Applicants are 

Missing Single Audits to assist with missing audits and next steps.

3. Program offices, after consultation with their program attorney, take action 

pursuant to any of the following as deemed appropriate 2 C.F.R. §§ 200.208, 

200.339, 200.340, and 200.341, when the grantee fails to submit the missing 

report by the established deadline, and all efforts to have the grantee submit 

the report have failed.

4. If the grantee has filed an audit report, and the audit report reveals findings, 

program offices follow up with the grantee to assess if the findings have been 

resolved and should follow policy in the Handbook for External Post Audit 

Process related to accessing Program Determination Letters (PDLs), 

addressing findings with grantees, issuing PDLs, and carrying out any other 

required process or activity related to audits. In some cases, the program 

offices recommend that the program official impose specific conditions on the 

grant and recommend additional monitoring and TA.

5. Program offices document the review of audit information, and all actions 

taken to bring the grantee into compliance with the audit requirements in the 

official grant file.

C. Guidance – Reserve

D. Other Pertinent Information

1. The Consolidated Substantial Progress Feed assists program offices with 

administering and managing ED grants by allowing them to view the “Audit 

Findings” page, which displays audit results and indicators from the FAC.

2. Twice per fiscal year, the Audit Resolution Division (ARD) within the OFO 

identifies grantees that have not submitted their audit to the FAC. ARD 

notifies program offices of the missing audits so program offices can follow-up 

with their grantees. Questions regarding missing audits can be directed to 

ARD at AuditResolutionDivision@ed.gov. 

3. The requirements addressed under Policy item 2 do not apply to For-Profit 

entities. Program offices may require a For-Profit entity to conduct an audit by 

imposing a specific condition. See the For-Profit Organizations section.
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6.3.7 Adverse Findings Requiring Consultation with Other Offices

A. Policy

1. Program offices, when monitoring reveals noncompliance with laws, 

regulations, or grant terms and conditions, work to bring the grantee into 

compliance by:

a. Providing TA;

b. Directing the grantee to make needed changes to the project; and

c. Recommending the program official take enforcement actions such as 

imposing specific conditions, route payment, high-risk status; withholding 

payment; or suspension, termination, recovery, or reimbursement of funds 

(see the section Enforcement).

B. Procedures

1. If issues are identified that seem systemic or cross-cutting that may affect the 

grantee’s administration of other associated ED grants in the areas of 

financial management, cash management, procurement, documentation of 

expenditures, subrecipient monitoring, or other issues, program offices 

consult with their RMSD State Liaison for coordination with other programs 

that may be affected.

2. If monitoring reveals an unallowable obligation under the grant, failure to 

account for funds properly, or the need for the recovery of funds, the program 

official works with other appropriate ED offices including ARD, OGC, and 

Budget Service to recover funds.

3. If findings require a follow-up audit, program offices refer such requests to the 

OIG.

4. Principal Officers report findings involving possible violation of Federal law or 

regulation not within their authority to resolve to OIG and other cognizant 

officials, such as the Assistant Secretary for Civil Rights for apparent 

violations of civil rights assurances, or to other Federal agencies.

C. Guidance – Reserved

D. Other Pertinent Information

1. The RMSD Lead List of Contacts by State can be found at RMSD State 

Leads. 
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6.3.8 Debarment and Suspension during Monitoring

A. Policy

1. Debarment and Suspension by ED is government-wide (see 2 C.F.R. part 

180 and 2 C.F.R. part 3485):

a. Suspension (usually less than 1 year) temporarily prevents a party from 

participating in most government-funded procurement and nonprocurement transactions pending completion of an investigation or legal 

proceeding.

b. Debarment is a final determination that a party is not presently responsible 

and thus ineligible (usually not to exceed 3 years) to participate in 

federally funded contracts or grants.

B. Procedures

1. Program offices monitor their assigned grant projects and identify, in 

consultation with their program attorney, apparent causes for suspension or 

debarment.

2. Once a program office, in consultation with their program attorney, identifies 

an apparent existence for suspension and debarment, it refers the apparent 

existence of a cause for debarment and suspension to GMPD for processing 

in accordance with the directive for debarment and suspension. 

3. Inquiries from program offices concerning persons debarred, suspended, 

voluntarily excluded, or determined to be ineligible by ED or another Federal 

agency are directed through the cognizant Principal Officer’s designee to 

GMPD. 

C. Guidance

1. When program offices, in consultation with their program attorneys, identify 

apparent causes for actions to be taken by ED that are more stringent than 

applying specific terms and conditions, increasing monitoring, or providing 

TA, they may consider that suspension and debarment are available 

administrative measures that may be taken to protect the public interest and 

safeguard the integrity of Federal programs by ensuring that the Federal 

government only conducts business with responsible entities and individuals. 

These measures protect taxpayers from fraud, waste, and abuse by allowing 

agencies to exclude entities and individuals that have shown to be unworthy 

of the public trust from receiving awards, contracts, grants and other sources 

of funding.
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D. Other Pertinent Information

1. GMPD is responsible for processing all non-procurement suspensions and 

debarments that do not relate to Federal Student Aid programs or that involve 

Certified Public Accountants (CPAs), CPA professional corporations, or CPA 

firms or partnerships (see ACSD-OFO-027, Nonprocurement Suspension and 

Debarment). 

6.3.9 Monitoring Reports

A. Policy

1. Program offices issue monitoring reports to grantees at the conclusion of 

formal monitoring in accordance with Program Monitoring Plans. 

B. Procedures

1. Program offices, after conducting formal monitoring, prepare a monitoring 

report based on the requirements of the program offices’ monitoring plans 

that accurately describes what was learned during the monitoring review as 

well as through desk monitoring.

2. Program offices store monitoring reports issued to grantees at the conclusion

of a monitoring review, and all other pertinent monitoring activity 

documentation, in the official grant file.

C. Guidance

1. The monitoring report is objective, focused on improving the productive 

relationship between ED and the grantee, and designed to help the grantee 

improve the management and implementation of its project. The monitoring 

report usually provides:

a. The purpose of the monitoring activity; 

b. The methods and instruments used during monitoring;

c. Documentation of all monitoring contacts;

d. An assessment of the activities that have been completed and the extent 

to which a grantee’s project scope and objectives have been met;

e. Specific elements of exemplary performance or best practices, if available; 

and

f. Information related to areas of noncompliance identified during the review, 

required corrective actions, recommendations for improvements, concerns 
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identified regarding the allowability of costs charged to grants, including 

concerns with documentation, and any TA to be provided in response to 

the monitoring review.

2. Program offices should consider drafting a transmittal letter to accompany the 

monitoring report that is to be issued at the conclusion of the formal 

monitoring activity, if the report does not otherwise capture information that 

could be conveyed in a transmittal letter.

3. Program offices have the discretion to issue monitoring reports to grantees 

when monitoring is conducted informally and continuously (see item 2 of the 

Monitoring Introduction section) by following the Policy and Procedures in this 

section, or may for this type of monitoring, choose to inform their grantees of 

monitoring results using alternative reporting methods deemed appropriate by 

the program offices.

D. Other Pertinent Information

6.4 Monitoring – Financial

A. Policy

1. Program offices monitor the financial activities of their grantees to ensure 

compliance with financial requirements.

2. The standards for financial management systems that grantees are required 

to follow are established in 2 C.F.R. § 200.302. The standards require 

grantees to maintain:

a. The identification, in their accounts, of all Federal awards received and 

expended, and the Federal programs under which the awards were 

received. Federal program and Federal award identification must include, 

as applicable, the AL title and number, Federal Agency Identification 

Number (FAIN) and year, name of the Federal agency, and name of the 

pass-through entity, if a pass-through entity exists;

b. Accurate, current, and complete disclosure of the financial results of each 

Federal award, or program, in accordance with established reporting 

requirements;

c. Records that identify the source and application of funds for federally 

funded activities. These records contain information pertaining to Federal 

awards, authorizations, obligations, unobligated balances, assets, 

expenditures, income, and interest earned.
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d. Source documentation (orders, receipts, rebates, etc.) for all financial 

transactions related to direct costs of the grant charged to Federal or 

matching funds;

e. Effective control and accountability over all funds, property, and other 

assets, to safeguard assets and ensure that they are only used for 

authorized grant purposes;

f. Records that show a comparison of expenditures with budgeted amounts 

for each award;

g. Written procedures for determining the allowability of costs in accordance 

with 2 C.F.R. part 200 subpart E, “Cost Principles” and the grant terms; 

and

h. Written procedures for minimizing the time between draws and 

disbursements in accordance with 2 C.F.R. § 200.305, “Payments.”

B. Procedures

1. Program offices establish financial management monitoring protocols for the 

grants they administer. At a minimum, these protocols should address the 

following:

a. Frequency of the monitoring;

b. Specific items to be reviewed; and

c. Risk mitigation strategies if issues are identified.

2. Program offices use the grants management system as the primary tool for 

fiscal oversight and may use information obtained from the ERR to assist in 

assessing financial monitoring needs. Program offices use the system to 

review expenditure information, such as payment histories and spending 

patterns, by PR/Award number or UEI.

3. Program offices review a grantee’s expenditure information no less than 

quarterly, and more frequently when the grantee is experiencing performance 

problems or when financial management issues are identified. Reviewing this 

information in the grants management system is the primary method of 

determining if the rate of cash draws is consistent with the expected 

expenditure pattern for a project’s approved scope of work and project 

milestones.
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C. Guidance

1. By detecting problems early in a budget or project period, program offices can 

work with grantees to resolve any issues involving cash drawdowns. Some 

questions the program offices should consider when conducting fiscal 

monitoring are:

a. Is the work being performed?

b. Are performance targets being met?

c. Is there a financial management problem?

d. Is the grantee making substantial progress?

e. Was the project start delayed?

f. Did the grantee have a difficult time hiring or replacing key personnel, 

including the project director?

g. Did key personnel leave the project?

h. Does the grantee understand Federal cash management policy, and ED’s 

procedures for drawing funds?

i. Is the rate of the grantee’s cash draws justified considering the nature of 

the project?

j. Has the grantee drawn few or no funds?

k. Is the grantee not drawing funds on a consistent basis?

l. Does the grantee have a large fund balance near the end of each quarter 

of a budget period?

D. Other Pertinent Information

1. Among the financial information in the grants management system that will 

assist program offices with fiscal monitoring is information about:

a. Excessive drawdown activity (see Excessive Drawdowns section);

b. Large available balances (see Large Available Balance section); and

c. Payment flags (see Payment Flags section). 
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6.4.1 Excessive Drawdown

A. Policy

1. Drawdowns are excessive if they exceed the amount of funds necessary for 

the grantee to meet its immediate cash needs for the grant. Program offices 

monitor drawdown activity to ensure that funds are drawn only to meet a 

grantee’s immediate cash needs for each individual grant.

2. Grantees minimize the amount of time between the drawdown and the use of 

funds from their bank accounts (see 2 C.F.R. § 200.305).

3. Grantee drawdown activity is flagged as potentially excessive if it meets the 

following thresholds established in the grants management system for each 

grant quarter:

a. First quarter: more than 50 percent of the funds for that budget period 

have been drawn by the end of the first quarter;

b. Second quarter: more than 80 percent of the funds for that budget period 

have been drawn by the end of the second quarter; and

c. Third quarter: 100 percent of the funds for that budget period have been 

drawn by the end of the third quarter.

B. Procedures

1. Every evening the grants management system compares drawdown activity 

against preset drawdown thresholds established and identifies grants that 

appear to have atypical drawdown patterns (i.e., excessive, or insufficient 

drawdowns).

a. Program officials have the flexibility to modify the percentage thresholds 

established in the grants management system that are used to measure 

drawdown activity when deemed appropriate and in consultation with the 

GMPD liaison. 

b. Program officials, in consultation with GMPD, justify the need for the 

change by explaining how the threshold change is supported by the grant 

program’s statute or regulations (i.e., a grant program’s statute or 

regulations require expenditure patterns that conflict with the preset 

thresholds).

2. Program offices log into the grants management system to “My Quick View, 

My Program Office Awards” or run the excessive drawdown report to monitor 

drawdown activity and to review for any grants identified as meeting the 

established thresholds for excessive drawdowns.
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3. When potentially excessive drawdowns have occurred, program offices 

review the drawdown data against the grantee’s approved budget and grant 

application to determine if an acceptable correlation exists between the large 

drawdown, the period it has occurred, and the budget period’s scheduled 

activities. If this review was insufficient to determine whether the drawdowns 

were excessive, program offices contact the grantee for additional information 

to support the drawdown.

4. After review, if program offices determine that the drawdown was not 

excessive, program offices summarize the review in the grants management 

system and in the official grant file, explaining how the drawdown is 

consistent with approved project activities and the approved budget.

5. However, if program offices determine that the drawdown is excessive, 

program offices contact the grantee immediately after the determination and 

inform the grantee that it must resolve the excess cash balance in their bank 

accounts resulting from the excessive drawdown within 14 calendar days.

6. Program offices instruct grantees to return excess cash balances to ED using 

the Create Refund functionality in the Payments Module or by making online 

adjustments which are the simplest and quickest methods for returning funds.

a. When using the Create Refund functionality to return excess cash 

balances, the grantee will select the following reason for the refund from a 

dropdown menu: “Returning funds associated with an Excessive 

Drawdowns determination.”

b. When funds are to be returned by check, program offices instruct grantees 

to include the PR/Award number, grantee UEI number, and the name and 

telephone number of the person authorized to resolve the excess balance 

issue on behalf of the grantee. The check is mailed to:

U.S. Department of Education

P.O. Box 979053

St. Louis, MO 63197-9000.

7. Once the excessive drawdown is resolved, program offices record the 

resolution in the comment field in the grants management system and check 

the resolved box. Program offices also document the resolution in the official 

grant file accordingly:

a. Indicate the date the grantee was contacted and notified of the excessive 

drawdown.

b. Indicate the date the grantee resolved the excess cash balance.
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c. Indicate if funds were: 1) returned to ED; or 2) the grantee made an online 

adjustment.

d. Indicate the specific condition or any other action taken as a result of the 

excessive drawdown, if any.

8. Program offices, during their contact with the grantee, inform the grantee of 

the correct cash management policies and regulations regarding drawdown 

and disbursement of funds (see 2 C.F.R. § 200.302 and 2 C.F.R. § 200.305).

9. On the 30th day of each month, GMPD generates the “Unresolved Excessive 

Drawdown Report” and sends it to program officials, or their designees. The 

report serves as ED’s official notification to program offices that their grantees 

continue to have an unresolved excessive cash balance beyond the 14-

calendar day timeframe.

a. Program officials, or their designees, distribute the “Unresolved 

Excessive Drawdown Report” to the appropriate program staff for 

research and immediate resolution.

b. The program official ensures that problems with excess cash balances 

are resolved, and that proper documentation regarding the status of each 

grant listed on the report is maintained in the grants management system

and in the official grant file.

10.Program staff inform their program official, if grantees on the Unresolved 

Excessive Drawdown Report still do not resolve excess cash after being 

contacted. The program official, after consultation with their program attorney, 

either imposes item a or item b below. Generally, item b is imposed if a 

grantee repeatedly draws down funds in excess of its immediate cash needs 

for the grant.

a. Activate the Route Payment Flag - Notify the grantee that all future 

payment requests will be routed to program offices for approval. Program 

offices approve drawdown requests only after the grantee has 

substantiated expenditures greater than the amount of the excess 

balances or has returned the excess cash balance from previous 

drawdowns.

b. Activate the Reimbursement Flag - Transferring the grant from the 

advance payment method to the reimbursement payment method which 

requires that the grantee be reimbursed for expenses incurred.

1) Program offices approve drawdowns only after the grantee has 

substantiated expenditures greater than the amount of the excess 

balances. If a new drawdown is appropriate, program offices bring
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supporting documentation to the license holder, who can then 

authorize payment.

2) A grantee assigned to reimbursement submits vouchers as proof of 

expenditures and explains why these expenditures are allowable.

11.The program official engages in additional consultation with their program 

attorney when the excess cash balances remain unresolved after taking one 

of the actions described above in item 10 of this section to determine whether 

to impose other specific conditions on the grant or grantee or designate the 

grantee as high-risk. 

12.When the grantee is designated high-risk, the program official notifies the 

grantee and activates the stop payment flag. Activating the stop payment flag 

will prevent the grantee from drawing down funds on an individual award, or if 

necessary, on any award made to the entity until the excess cash issue has 

been resolved.

C. Guidance

1. Program officials, or their designees, have the flexibility to modify the 

percentage thresholds that are used to measure drawdown activity when 

deemed appropriate and in consultation with the GMPD liaison. 

2. Program officials may use the “Excessive Drawdown Report” available in the 

grants management system as a tool to assist with their ongoing monitoring 

of a grantee or grant program. The report contains a listing of the grants that 

continue to have unresolved excessive drawdowns for a period of 15 calendar 

days or more. The system also provides an “Award History Report” that may 

be used to supplement the review of the “Excessive Drawdown Report.”

3. Even if grants are not identified in the Excessive Drawdown Report, grantees 

may still be making excessive drawdowns if the drawdowns exceed their 

immediate needs.

D. Other Pertinent Information

1. If interest has been earned as a result of the excessive drawdown in excess 

of $500 per year on Federal cash balances, it must be returned accordingly:

a. The preferred method to return interest is through Automated Clearing 

House (ACH) Direct Deposit or Fedwire. 

1) When returning interest through ACH Direct Deposit or Fedwire, 

grantees must include the following in their return transaction: 
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a) PMS Account Number (PAN). NOTE: The PAN is the same series 

of alpha-numeric characters used for payment request purposes 

(e.g.: C1234G1). 

b) PMS document number. 

c) The reason for the return (e.g. interest, part interest part other, 

etc.). 

d) An explanation stating that the refund is for interest payable to the 

Department of Health and Human Services, and the grant 

number(s) for which the interest was earned. 

2. U.S. Department of Education grantees are generally located and operate 

domestically and return interest domestically. Below is PSC ACH account 

information for interest returned domestically. For international ACH interest 

returned, account information is available at: Returning Funds/Interest. 

a. PSC ACH Routing Number is: 051036706 

PSC DFI Accounting Number: 303000 

Bank Name: Credit Gateway - ACH Receiver 

Location: St. Paul, MN 

3. Service charges may be incurred from a grantee’s financial institution when a 

Fedwire to return interest is initiated. For FedWire returns, Fedwire account 

information is as follows: 

a. Fedwire Routing Number: 021030004 

Agency Location Code (ALC): 75010501 

Bank Name: Federal Reserve Bank 

Treas NYC/Funds Transfer Division 

Location: New York, NY 

b. Interest may be returned by check using only the U.S. Postal Service; 

however, returning interest via check may take 4-6 weeks for processing 

before a check payment may be applied to the appropriate PMS account. 

A brief statement explaining the nature of the return must be included.

c. Interests returned by check are to be mailed to: 

HHS Program Support Center 

PO Box 979132 

St. Louis, MO 63197 

4. To return interest on a grant not paid through the PMS, make the check 

payable to the Department of Health and Human Services, and include the 

following with the check: 
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a. An explanation stating that the refund is for interest 

b. The name of the awarding agency 

c. The grant number(s) for which the interest was earned 

d. The return should be made payable to: Department of Health and Human 

Services. 

e. For detailed information about how to return interest, visit the PSC 

Retuning Funds/Interest page at: Returning Funds/Interest 

5. GMPD is responsible for providing department-wide oversight to ensure that 

program offices are monitoring for excessive drawdowns.

6.4.2 Payment Flags

A. Policy

1. ED policy allows program offices to apply any of the following three payment

flags to grants to prevent inappropriate drawdowns or when information about 

a grant reveals fiscal (e.g., improper payments to the grantee) or other 

problems associated with the grant:

a. Route Payment - requires that program offices review and approve a 

grantee’s drawdown request before funds are released;

b. Reimbursement - requires that a grantee use its own funds and provide 

receipts or other documentation of allowable expenditures to program 

offices before funds are released by a reimbursement analyst (license 

holder with this role) to the grantee; and

c. Stop Payment - prevents a grantee from drawing any funds on the grant 

and should generally be used only as a short-term measure.

2. Program offices’ monitoring and risk reviews include examining payment flag 

information to determine if a grant’s UEI is associated with a grant that has 

been assigned a payment flag, and to consider if the same conditions that 

resulted in the payment flag on the associated grant also apply to the grant 

being monitored or reviewed for risk.

B. Procedures

1. When a grant is associated with another grant having a payment flag, 

program offices contact the program staff managing the other grant for a 

status update about the corrective action(s) taken to address the issue(s) that 
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resulted in the payment flag to determine whether the same conditions apply 

to both grants.

2. When program offices determine that conditions warrant assigning a payment 

flag, they consult with both the program official and program attorney for 

concurrence.

3. If, after consultation with the program official and the program attorney, it is 

deemed appropriated to activate a payment flag, program offices immediately 

thereafter notify the grantee in writing of:

a. The type of payment flag activated;

b. The reason(s) the payment flag has been activated; and

c. The requirements that must be met in order to remove the payment flag.

4. If program offices decide, after consultation with their program attorney, that a 

specific condition be issued in relation to the payment flag, program offices 

record the specific condition and issue a GAN reflecting the specific condition.

5. When program offices activate payment flags, they select the reason for 

activating the payment flag from a dropdown list and provide further 

explanation for the flag in the associated comment field.

6. Program offices document all applicable discussions and decisions in the 

grant file.

C. Guidance

1. Program offices may use the ERR, the Inquire Award Payment flags 

functionality, or the “My Quick View, My Program Office Awards” page in the 

grants management system to review awards with payment flags.

2. When program offices receive inquiries from other ED offices related to a 

grantee’s payment flags, the inquiries should be considered urgent and a 

timely response should be provided, so that awards, administrative actions or 

other performance and compliance matters are addressed quickly and 

appropriately.

D. Other Pertinent Information

1. Entering an explanation in the associated comment field related to the 

payment flag activated will assist other program offices address similar issues 

pertinent to grants falling under their auspices, because they will be able to 

access the payment flag and related explanation.
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6.4.3 Large Available Balance

A. Policy

1. Program offices review the “Large Available Balance Report” prior to issuing 

NCC awards, but no more than 90 days before the end of the budget period. 

The “Large Available Balance Report” flags grants where 70 percent of the 

project budget is available 90 days or less before the budget period ends.

2. The “Large Available Balance Report” has a default setting of 70 percent. 

Program offices, by modifying the Subprogram record, set a lower threshold 

to identify large available balances, but in no instance increase the threshold 

to exceed 70 percent.

3. Program offices do not accept a grantee’s notification of a time extension 

without reviewing the “Large Available Balance Report” and resolving any 

identified issues.

B. Procedure

1. Not more than 90 days before the end of the budget period, program offices 

generate the “Large Available Balance Report”.

2. Not more than 90 days before the end of the budget period, and prior to 

rolling over the award, program offices contact the grantees for resolution, if 

large available balances exit.

3. Program offices contact grantees with large available balances to ascertain 

the reasons for the balances. At a minimum, program offices request 

information for:

a. The total amount of the available balance that is already obligated 

(including documentation from the grantee);

b. Any activities that were originally planned for the current budget period but 

were not conducted;

c. The grantee’s anticipated drawdowns during the remainder of the current 

budget period; and

d. The grantee’s planned use of the funds during the subsequent budget 

period.

4. Program offices require grantees with large available balances to submit the 

information outlined above, and any other relevant information, in writing.
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5. Program offices, based on the information provided, determine an appropriate 

resolution, if necessary, before issuing an NCC. Potential options for 

resolution include:

a. Increased monitoring, including requiring the grantee to submit 

performance and expenditure reports more frequently;

b. TA to the grantee to address any issues contributing to the large available 

balance;

c. Specific conditions on the grant award to address any serious 

performance, management, or financial issues contributing to the large

available balance;

d. A reduction in the amount of the NCC award; and

e. Not making an NCC award.

6. When determining an appropriate resolution, program offices consider 

whether the grantee can simultaneously perform grant activities it did not 

complete in the prior budget period while also pursuing activities planned for 

the new budget period, or whether recommending a reduction of the NCC 

award is a more appropriate action.

7. If program offices determine that it is appropriate to allow the grantee to use 

the large available balance, they must reach an agreement with the grantee 

for a revised budget plan prior to making a recommendation to the program 

official.

8. Program offices include any documentation addressing the large available 

balance and resolution (including the information described in item 1 above) 

in the official grant file.

9. Program offices provide large available balance and resolution documentation 

required in the NCC Funding Slate Memo Template for NCC funding 

approval.

C. Guidance

1. Large balances remaining in grant accounts at the end of a budget period 

may indicate non-performance or financial mismanagement. However, having 

a large available balance does not always mean there is a problem, or a 

failure on the part of the grantee. Some grantees use their own funds and 

reimburse themselves with funds from their ED account. Other grantees draw 

funds from the accounts on set schedules, such as monthly or quarterly 

according to the accounting and cash management procedures of the 

organization.
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2. The program official may designate an individual to generate the “Large 

Available Balance Report” for an entire program office and assign the 

program staff responsible to research each grant on the report, and work with 

the grantee for resolution.

3. The “Large Available Balance Report” may be generated 90 days before the 

end of the budget period. If there are varying budget period end dates on 

grants within the same program office, the report may be run on a recurring 

basis to ensure that all the grants can be evaluated based on the “Large 

Available Balance Report” criteria.

4. Program offices may run the “Large Available Balance Report” at any time for 

monitoring purposes.

5. Program offices may also use the optional Consolidated Substantial Progress 

Feed functionality in the grants management system, which is an 

administrative tool that will automatically notify grantees via email of a 

remaining balance if more than 70% (the default percentage) of the budget 

remains on the last day of the 3rd quarter of the award budget period.

a. The email to grantees requires them to provide:

1) The amount unliquidated;

2) Grant funds expected to be obligated for the remainder of the current 

budget period; and

3) A projection of the Federal share of grant funds that will not be 

obligated before the end of the current budget period.

b. When using the Consolidation Substantial Progress Feed functionality, 

program offices can control whether emails are to be sent to their grantees 

and may set a threshold different than the 70% default by modifying the 

Subprogram record.

D. Other Pertinent Information

1. Program offices should refer to the section Carryover for additional 

information about addressing available balances prior to awarding NCCs.

2. Program offices follow the procedures in the section Extensions of the 

Final Budget Period when grantees are in the final budget period of their 

grants and extensions are being considered to expend available balances.
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6.4.4 Cost Sharing and Matching Contributions

A. Policy

1. Program offices monitor whether grantees are meeting their cost sharing and 

matching commitments.

2. Program offices ensure that costs contributed by a grantee to a project as a 

cost sharing or matching item meet the same standards for reasonable, 

allocable, and allowable as those items supported by Federal dollars.

3. Program offices ensure grantees’ cost sharing and matching comply with the 

grant program’s statutes and regulations.

4. With the Secretary’s approval, program offices may waive a grantee’s cost 

sharing or matching required in a program’s statute or regulations when the 

statute or regulations state the authority to waive program requirements. 

However, unless well-justified by the grantee, the Secretary does not, as a 

general matter, waive cost sharing or matching due to the importance of 

required cost sharing or matching to the long-term success of a grant project.

5. In accordance with 2 C.F.R. § 200.1, cost sharing or matching are treated 

alike at ED.

B. Procedure

1. When conducting post-award monitoring of matching commitments, whether 

those commitments are statutorily required or voluntary committed (see 

section Grantee Cost Sharing or Matching (Non-Federal Share), program 

offices review audits performed and applicable Program Determination 

Letters (PDL) for match related findings requiring resolution.

a. For matching that is neither statutorily required or voluntary committed, the 

match is not considered cost sharing or matching. Therefore, 

modifications to these matching amounts can be made if the goals and 

objectives of the project are not changed.

2. Program offices ensure that grantees are able to justify that the costs used to 

meet cost sharing and matching requirements are allowable under the cost 

principles in 2 C.F.R. part 200 subpart E, including the requirement that the 

costs must serve an objective of the grant.

3. Program offices ensure that grantees’ matching contributions (both cash and 

third party in-kind) meet the following criteria:

a. Verifiable from the recipient’s records.
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b. Not included as a contribution for any other Federally assisted project or 

program (i.e., a matching contribution applied to one grant cannot be 

applied to another).

c. Necessary and reasonable for the proper and efficient accomplishment of 

project or program objectives.

d. If a cost would be allowable in the Federal budget, it would be allowable in 

the non-Federal budget as a matching contribution. Likewise, if a cost 

would not be allowable in the Federal budget, it would not be allowable in 

the non-Federal budget as a matching contribution.

e. Not paid by the Federal Government under another award (except where 

authorized by statute for both the grant program receiving the matching 

funds and the other Federal program providing the match).

f. The application of matching to a Federal grant must be consistent with the 

grantee’s application of those costs to Federal and non-Federal projects 

alike. If the grantee’s organization normally treats a cost for an activity as 

an indirect cost, the same cost is treated as an indirect cost for matching 

purposes.

g. Grantees must be careful not to contribute indirect cost categories items 

as a cost sharing or matching that are already included and covered in the 

indirect cost pool that was used as the basis for calculating the grantee’s 

federally approved indirect cost rate.

h. The budget for the items that the grantee contributes as a cost sharing or 

matching should be developed and shown separately from the federally 

funded portion of the budget, in accordance with the instructions for the 

ED 524 A & B forms (Budget Summary). These forms are included in 

grant application packages and completed and submitted with grant 

applications.

i. Indirect costs of institutions of higher education and non-profit 

organizations that are not recovered on training grants because those 

costs are limited to a maximum indirect cost rate of 8% of modified total 

direct costs may not be included as part of matching (see EDGAR § 

75.5629(c)(3)).

j. If a grantee decides to not charge the Federal award for the full indirect 

costs to which it is entitled and there are no requirements that limit the 

amount of indirect costs the grantee can recover, it may apply the 

unrecovered indirect costs to its matching budget, but only with prior 

approval (see 2 C.F.R.§ 200.306(c)).
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k. Program income is used to finance the non-Federal share of the project, if 

authorized in the terms and conditions of the award. Grant Award 

Attachment 6, Request for Approval of Program Income, a standard 

attachment used on all new and NCC award GANs, provides grantees 

three options for handling program income, one of which permits using 

program income for cost sharing and matching purposes to finance the 

non-Federal share of the project or program (see Grant Award Attachment 

6 and 2 C.F.R. § 200.307).

4. The decision to waive a grantee’s required cost sharing or matching is 

determined by the program official, after consultation with their program 

attorney, and recorded in the program office’s NCC Grant Funding Slate.

a. If a POC has a large program that has numerous grantees requesting 

different waivers for different economic needs or circumstances, program 

offices use a roll-up sentence in the Grant Funding Slate (e.g., “30 

grantees are requesting waivers...”), provides the reasons the waivers are 

being requested, and provides a justification for granting the waivers.

b. When a waiver occurs early in the budget period, and thus, it will not be 

addressed in the program office’s NCC Grant Funding Slate, program 

offices will submit an “Amendment” to the original Grant Funding Slate 

addressing the waiver and will include the original slate (via an 

attachment) for the competition for full context.

C. Guidance – Reserved

D. Other Pertinent Information

1. Refer to the Waiving Required Cost Sharing and Matching section for 

information regarding waiver request and approval.

2. For guidance regarding the valuation of a grantee’s cost sharing and 

matching contribution see the document titled, “Valuation and Documentation 

of Grantee Cost-share and Matching Contributions” at the following link: 

Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process. 
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6.5 Monitoring - Subaward and Executive Compensation Reporting 

Required by FFATA

A. Policy

1. Program offices monitor grantees to ensure compliance with the Federal 

Funding Accountability and Transparency Act (FFATA) reporting 

requirements, and if appropriate, take the necessary steps to ensure 

compliance, such as imposing specific terms and conditions, when grantees 

are negligent in their reporting.

2. FFATA requires, notwithstanding certain exclusions, that subaward and 

executive compensation data be reported for all new grants funded at 

$30,000 or more. For detailed reporting requirements see the “Subaward and 

Executive Compensation Reporting Required by FFATA Fact Sheet” (FFATA 

Fact Sheet) available at Documents and Forms Referenced in the Handbook 

for the Discretionary Grant Process. 

3. FFATA requires that grantees report subaward and executive compensation

data in the Federal Subaward Reporting System (FSRS).

B. Procedures

1. Program offices generally will not have access to grantee annual gross 

revenues, or income sources and levels, thus making it difficult to determine if 

executive compensation data must be reported by the grantee for itself or its 

subrecipients. Nevertheless, program offices remind their grantees of their 

obligation to report executive compensation when the requirements for 

reporting as addressed in FFATA are applicable to the grantees (see the 

FFATA Fact Sheet).

2. Subaward data reported in FSRS by grantees will post in USASpending.gov, 

which program staff routinely access during monitoring to ensure that timely 

reporting is occurring. Since program offices possess knowledge regarding 

grant obligation dates and amounts and should also know which grantees are

sub-awarding based on information provided in their grant proposals and 

grant budgets, program offices will be able to verify the reporting of 

subawards in accordance with FFATA in USASpending.gov. 

3. If program offices deem it appropriate to impose a specific term or condition 

upon a grantee that has been negligent in its reporting, they consult with the 

program attorney about the need for the specific condition.
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C. Guidance – Reserved

D. Other Pertinent Information

1. Grantees are notified of their requirement to comply with FFATA through the 

applicable GAN attachment included with new GANs. Grant Attachment 9, 

Federal Funding Accountability Transparency Act Reporting Subawards and 

Executive Compensation, incorporates grant terms and conditions, as 

established by OMB, that address subaward and executive compensation 

reporting requirements. The attachment is available for inclusions with GANs 

and is also available for information purposes at the following link: Grant 

Attachments and Enclosures. 

6.6 Monitoring – Contracts and Procurements 

A. Policy

1. All recipients of Federal funds must maintain policies and procedures for 

procuring goods and services, and ensuring contractor conformance with the 

terms, conditions, and specifications of contracts. A State or State agency 

(including a SEA) uses its own policies and procedures for procuring goods 

and services under a Federal grant. All other grantees and subrecipients may 

use their own procurement procedures, so long as they comply with 

applicable State and local laws and regulations, and the Federal standards 

set forth in 2 C.F.R. §§ 200.317 through 200.327. 

B. Procedures

1. As program offices monitor contract administration for compliance, they 

consider, as established by 2 C.F.R. part 200 Subpart F, “Audit 

Requirements,” that procurement is a compliance area tested as part of a 

grantee’s single or program- specific audit, and if findings were noted, they 

regularly request status updates from the POC‘s Audit Liaison Officer or the 

Audit Resolution Division (ARD) for progress on applicable outstanding 

corrective actions to verify that progress benchmarks and timelines are being 

met. 

a. Program offices follow the processes in the Handbook for External Post 

Audit Process for a specific audit or for an audit that covers multiple 

programs. The most common types of findings related to procurement 

include insufficient policies and procedures, incomplete transaction files 

and documentation, and failures to check contractors against the Federal 

debarment and suspension list.

2. Other monitoring activities related to contract administration and procurement 

could include: 1) discussing procurement as a part of routine monitoring calls 
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and visits; 2) performing a desk review of the grantee’s procurement policies 

and procedures; 3) testing a sample of contract files against the 

organization’s procurement policies and Federal requirements; 4) increasing 

the frequency and scope of monitoring efforts; or 4) scheduling an onsite visit 

to verify compliance.

C. Guidance – Reserved

D. Other Pertinent Information

1. Program offices should be aware that a grantee’s failure to adequately 

document procurement transactions and monitor contractors has serious 

repercussions, because it can lead to poor program performance, or to the 

fraud, waste, or abuse of grant program funds.

6.7 Non-Competing Continuation (NCC) Awards

6.7.1 Evaluating Risk Prior to Making NCC Awards

A. Policy

1. Program offices conduct risk evaluations for grantees before obligating their

NCC awards.

B. Procedures

1. Program offices use the factors below when determining how detailed a risk 

evaluation to conduct and have discretion in how much additional analysis 

and follow-up is necessary based on the grantee’s unique circumstances and 

history. Program offices consider:

a. The amount of time that has passed since the last risk evaluation;

b. Whether risk issues were previously identified, and risk mitigation 

strategies implemented;

c. The grantee’s progress in addressing the risk issues identified; and

d. Any applicable information garnered from the relationship established

between the grantee and program staff.

2. If programs offices monitoring efforts reveal risks have not changed since the 

prior risk evaluation, the grantee’s progression towards addressing risks is on 

target, and no new risks are identified, program offices summarize these facts 

in their NCC Grant Funding Slate.
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3. Program offices conduct a more detailed assessment when new risks are 

identified, or the grantee is failing to mitigate risks in accordance with 

applicable specific risk-related conditions and/or risk mitigation strategies that 

were implemented during the previous risk evaluation.

4. In addition to identifying new risks, program offices consider if any specific 

risk- related condition or other risk mitigation action is to be continued, 

amended, removed, or supplemented by another specific risk-related 

condition or risk mitigation action, in consultation with their program attorney.

5. Program offices consider, when conducting a risk evaluation, prior and 

current financial and performance information, and compliance with Federal 

audit requirements, audit findings, progress in achieving corrective actions set 

in place to resolve audit findings, compliance findings, and other

administrative issues.

6. Program offices consider any issues or concerns identified through day-today oversight, routine monitoring, and TA efforts that might adversely affect a 

grantee’s performance under an NCC award.

a. If risks are identified that require specific award conditions, a program 

official, after consultation with the program attorney, imposes specific 

award conditions on an NCC award in accordance with 2 C.F.R. § 

200.208, or designates the specific award conditions as “high-risk” 

conditions, and designates the grant or grantee high risk in accordance 

with 2 C.F.R. § 200.208 and 2 C.F.R.§ 3474.10. 

C. Guidance

1. The following is a list of factors that may be considered when evaluating 

grantee risks before obligating NCC awards. This is not an all-inclusive list, 

and program offices may identify additional items for consideration as they 

conduct risk evaluations:

a. Has the grant or entity been designated high-risk? 

b. Is the grantee implementing its project in accordance with any specific 

risk- related conditions or risk mitigation strategies previously imposed 

upon the grant award?

c. Were there any excessive drawdowns or unallowable costs during the 

previous budget period?

d. Is there a large available balance which will result in a carryover amount?

e. Has there been turnover of key personnel?
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f. Has substantial progress been made, if not why?

g. Have all required reports been submitted?

h. Has progress been made on corrective actions, if applicable?

i. Are there any 2 C.F.R. part 200, subpart F Audit Findings, and is the 

grantee making progress in resolving those findings?

j. Is the grant on schedule to achieve its objectives?

k. Will a no-cost extension be needed?

2. Program staff can consider ERR data when evaluating risk prior to awarding 

NCCs (see the section Evaluating Grant Applicant Risk Prior to Making a New 

Award). 

D. Other Pertinent Information

1. For information about imposing specific conditions, and the requirements for 

notifying a grantee (see the section Grant Performance – Addressing Risk 

and Other Issues).

2. The requirements for designating a grantee high risk and the requirements for 

notifying a grantee of a high-risk designation are addressed in the section 

Grant Performance – Addressing Risk and Other Issues.

3. Program offices may use the Risk Rubric Guide when evaluating risk for NCC 

awards. The Risk Rubric Guide provides a framework that allows flexibility to 

address specific issues, or risks while also providing a consistent, methodical 

approach to evaluating risk levels for a single grant or within a grant program.

6.7.2 Reviewing Audit Data Prior to NCC Awards

A. Policy

1. Program offices review available audit information prior to issuing NCC 

awards to ensure that required audits were submitted, and any findings and 

recommendations are resolved or being appropriately addressed by the 

grantee.

2. Single or program-specific audits are required for entities expending Federal 

assistance equal to or in excess of $750,000 during the entity’s fiscal year 

(see 2 C.F.R. § 200.501).
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B. Procedures

1. Program offices review available audit information during monitoring by 

accessing audit information using one or more of the following resources: 1) 

the Federal Audit Clearinghouse (FAC) database; 2) consulting with an audit 

specialist in the Audit Resolution Division (ARD) or the POCs audit liaison 

regarding information within ED’s Audit Accountability and Results Tracking 

System (AARTS); 3) by reviewing audit information contained in ERRs; or 4) 

by accessing audit information using the Consolidated Substantial Progress 

Feed. 

2. Program offices contact the grantee to inquire about the status of the missing 

audit report if the review of the audit data reveals that a grantee that is subject 

to the audit filing requirements of 2 C.F.R. part 200 Subpart F, “Audit 

Requirements” has failed to comply with the filing requirement, and if 

necessary, establish a deadline for the grantee to submit the report to the 

FAC.

3. Program offices consult with the program attorney regarding any actions or 

sanctions to address missing reports and noncompliance before taking any 

final actions, and documents in the official grant file all actions taken to bring 

the grantee into compliance.

4. Program offices, in consultation with the program attorney, decide whether to 

issue an NCC award, or take other enforcement actions, pursuant to 2 C.F.R. 

§§ 200.208, 200.338, and 200.340, when the grantee has failed to submit the 

report by the established deadline, and all efforts to have the grantee submit 

the report have failed.

5. If the grantee has filed an audit report, and the audit report reveals findings, 

program offices contact the grantee to determine if the findings were 

resolved, and in the event, findings are unresolved, program offices follow 

policy in the Handbook for the External Post Audit Process. 

a. Program offices consult with their POC audit liaison for information in 

AARTS and/or contact an audit resolution specialist in ARD to discuss 

findings, Program Determination Letters (PDLs), and other appropriate 

resolutions, and follow all other applicable procedures in the Handbook for 

the External Post Audit Process. 

6. Program staff, after discussions with ARD and after consulting with their 

program attorney, may need to recommend that the program official impose 

specific conditions on the grant or that additional monitoring and TA is 

needed.
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C. Guidance – Reserved

D. Other Pertinent Information

1. The Consolidated Substantial Progress Feed assists program offices with 

administering and managing ED grants by allowing them to view the “Audit 

Findings” page, which displays audit results and indicators from the FAC.

2. Twice per fiscal year, the Audit Resolution Division (ARD) within the OFO 

identifies grantees that have not submitted their audit to the FAC. ARD 

notifies program offices of the missing audits so program offices can follow-up 

with their grantees. Questions regarding missing audits can be directed to 

ARD at AuditResolutionDivision@ed.gov. 

3. The requirements addressed under Policy item 2 do not apply to For-Profit 

entities. Program offices may require a For-Profit entity to conduct an audit by 

imposing a specific condition. See the For-Profit Organizations section.

6.7.3 Reviewing Information in FAPIIS Prior to Making NCC Awards

A. Policy

1. Program offices review and consider information about grantees in FAPIIS if 

the grants exceed or will exceed, over the course of the grant project periods, 

the simplified acquisition threshold. This review is conducted before making 

NCC awards that exceed the simplified acquisition threshold. Currently, this 

threshold is $250,000.

2. Before awarding an NCC grant, program offices, at a minimum, determine 

that the FAPIIS information: 1) demonstrates a satisfactory record of 

executing programs or activities under Federal grants, cooperative 

agreements, and procurement awards; and 2) demonstrates integrity and 

good business ethics (see 2 C.F.R. § 200.205).

B. Procedures

1. For required procedures related to FAPIIS reviews see the section FAPIIS 

Information Review Requirements. 

C. Guidance

1. For applicable guidance related to FAPIIS reviews see the section FAPIIS 

Information Review Requirements. 
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D. Other Pertinent Information

1. For other pertinent information related to FAPIIS reviews see the section 

FAPIIS Information Review Requirements. 

6.7.4 Making Non-Competing Continuation (NCC) Awards

A. Policy

1. Program offices ensure that grantees of multi-year discretionary awards 

submit an annual grant performance report that provides the most current 

performance and financial expenditure information (including cost sharing or 

matching data, if applicable) in accordance with EDGAR § 75.118. 

2. Program offices ensure that data submitted in the annual grant performance 

report specifically address whether the status of the funded project is aligned 

with the scope and objectives established in the approved application and any 

approved amendments.

3. Unless additional requirements are imposed by the program statute or 

regulations, under EDGAR § 75.253, NCC funding is contingent upon the 

following requirements:

a. Congress has appropriated sufficient funds under the program (see 

EDGAR § 75.253(a)(1));

b. The grantee has made substantial progress towards achieving the goals 

and objectives of the project, and the grant’s performance targets (see the 

section Substantial Progress and EDGAR § 75.253(a)(2));

c. The grantee submitted all required reports (including the required annual 

grant performance report) (see the section Grant Performance Reports 

and Due Dates and EDGAR § 75.253 (a)(3));

d. Program offices have determined that continuing funding is in the best 

interest of the Federal government (e.g., the program staff believes the 

project continues to serve the priorities of the program) (see EDGAR § 

75.253 (a)(4)); and

e. Program offices have determined that the grantee has maintained 

financial and administrative management systems that meet requirements 

in 2 C.F.R. § 200.302, Financial management, and in 2 C.F.R. § 200.303, 

Internal controls. 

4. Program offices do not obligate funds for an NCC award when a grantee’s 

UEI registration in SAM is inactive. Program offices will receive an error 

message in the grants management system at the time of obligation, and 
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immediately contact the grantee for resolution. Program offices only use the 

pre-award exempt functionality for situations where a genuine exigency, such 

as the potential that funds will lapse if funds are not awarded immediately, is 

present when awarding NCCs (see the section UEI Registration Review in 

SAM – General) 

5. For NCC awards that are to be frontloaded, the proposal to frontload these 

grants is documented in the program office’s spending plan and approved by 

the Budget Service (with the concurrence of OPEPD/GPO and OS). (See the 

Frontloading versus Forward Funding section).

B. Procedures

1. Program offices document the process for determining suitability and size of 

the NCC awards. The process should include standards that are appropriate 

for the uniqueness of the program, and which reflect the policies and 

procedures in the Substantial Progress and Setting the NCC Award Amount

sections. 

a. OPEPD/GPO will engage with program offices regarding their processes 

for determining the suitability and size of NCC awards to support 

consistency across ED.

2. The Secretary does not have to approve NCC awards when program offices 

can demonstrate that they have:

a. Conducted thorough reviews of each grantee’s APR, budget, and any 

other information pertinent to the grantee’s likelihood of achieving its goals 

and objectives, and performance targets of the grant.

b. Documented the NCC review in the program’s Grant Funding Slate 

memorandum (see the Developing Funding Recommendations section). 

c. Consulted with OPEPD/GPO before submitting the Grant Funding Slate 

memorandum for approval to the program’s Assistant Secretary (or 

equivalent).

3. If program offices determine that an NCC should not be awarded or the 

requested amount of the NCC award should be reduced (see the section 

Setting the NCC Award Amount), then program offices consult with their 

program attorney and OPEPD/GPO.

4. Program offices make determinations for NCC awards no earlier than 90 days 

before the end of a grantees budget period.
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C. Guidance

1. Program offices, when determining NCC awards, should consider the 

following factors:

a. Fiscal history and performance history (see sections Annual Performance 

Reports and Due Dates, Research Performance Progress Report, Federal 

Financial Report SF 425 (FFR), and Substantial Progress, as applicable).

b. Available information about risk (see the section Evaluating Risk Prior to 

Making NCC Awards).

c. Available funds and planned use for any carry over balance (see the 

sections Setting the NCC Award Amount and Carryover).

D. Other Pertinent Information

1. For the regulations that address requirements for SAM registration see 2 

C.F.R. Part 25. 

6.7.5 Annual Performance Reports and Due Dates

A. Policy

1. Program offices require the submission of an Annual Performance Report 

(APR) and direct grantees to use the Grant Performance Report form (ED 

524B29), to submit their grant performance and financial data to ED, unless 

additional information is needed beyond that requested on the report form, or 

program statute or regulations require the submission of another reporting 

form.

B. Procedures

1. When program officials decide that additional reporting information is 

necessary beyond that requested in the ED 524B, or when program statutes 

or regulations require the submission of a different reporting form, programspecific performance report forms are developed, and they must also request 

the budget and indirect cost information that is requested on the ED 524B.

29 The ED 524B, which is used to report performance prior to continuation funding as is reflected in this 

section, is not to be confused with the U.S. Department of Education Budget Information NonConstructions Program Form 524 Sections A, B, C, and D. The U.S. Department of Education Budget 

Information Non-Constructions Program Form 524 Sections A, B, C, and D captures budget and indirect 

cost information; however, this form is submitted by grant applicants when they submit grant applications 

for funding.
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2. When program offices develop program-specific performance report forms, 

they obtain approval from SCC and OMB in accordance with the Paperwork 

Reduction Act.

3. The minimum time to get a form (or any other request to collect information) 

approved by OMB is 120 days after SCC publishes the first of two required 

FR notices requesting comments on the proposed collection (see ICCS Guide 

to the Information Clearance Process).

4. Programs officials:

a. Establish the due date for grantees to submit their annual and/or interim 

ED 524B or program-specific performance reports for each program they 

administer.

1) The established submission date for the annual report must be as late 

in the budget period as reasonably possible.

2) Established submission dates should be designed to ensure grantees 

have adequate time to conduct enough project activities prior to 

submission of the report to allow program offices to make a reasonable 

assessment of the grantees’ progress. Generally, program offices 

require grantees to submit their annual reports seven to ten months 

after the start of the budget period; however, report due dates may 

vary based on program requirements, special circumstances, and 

whether reports are submitted electronically.

3) Program offices may vary due dates for performance reports based on 

project start dates, and not solely to align reporting dates across 

programs.

b. Establish a process for receiving and uploading into the grants 

management system annual and/or interim ED 524B reports when the 

reports are not submitted electronically by the grantee.

5. Program offices inform grantees of the date when their annual and/or interim 

ED 524B or program-specific performance reports are due. Notification is 

provided within the first GAN issued to the grantee for the grant project, or 

under a separate notification as deemed appropriate by the program official 

within 30 calendar days after start of the project period, or during the postaward conference, and within subsequent NCC GANs.

a. The instructions for submitting the reports must clearly state where the 

reports are to be submitted. If the reports are not to be submitted through 

the grants management system then the reports are either sent directly to 

the program staff member assigned to the grant, or to a central location 

designated by the program office.
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b. When changes to report due dates are necessary, program offices notify 

grantees of any changes to due dates as soon as possible.

C. Guidance

1. The ED 524B may be submitted in either hard copy or electronically; 

however, electronic submission is encouraged. Program offices can create 

the ED 524B for their grant programs in the grants management system, and 

when grantees submit their report, the system generates a notice to the 

grantee confirming the receipt of their report followed by an email 

confirmation message. Other benefits to the submission of the ED 524B in the 

grants management system include:

a. For those programs that include the U.S. Department of Education Grant 

Application Form for Project Objectives and Performance Measures 

Information (OMB Form 1894-0017) in their application packages, and that 

also require the submission of the ED 524B in the grants management 

system, the system will retrieve project objectives, measures, and targets 

entered into this form by applicants and populate this information into the 

corresponding ED 524B. The OMB Form 1894-0017 eliminates the need 

for grantees to reenter their objectives, measures, and targets when they 

complete and submit their ED 524B annual or final performance reports.

b. The electronic form provides program staff the ability to generate the 

following reports that allow data extraction capabilities for monitoring and 

analysis purposes.

1) Project Objectives Extract: The grants management system will 

provide a raw data extract of all project objectives and performance 

measure information filtered by PR/Award No, AL/Subprogram, 

Program Office and/or Keyword. The keyword search applies to only

the project objectives content. This extract is designed to be used for 

data analysis conducted outside of the grants management system

application.

2) Project Objectives Activity Report: The grants management system

will provide a project objectives modification activity report filtered by 

AL/Subprogram, Program Office, Keyword and Date Range. The 

keyword search applies to only the project objectives content. This 

report will display PR/Award No, Grantee Name, Last Modified date

and Last Modified by data. This report is designed to be used by 

program staff to identify changes to project objectives.

3) Project Objectives Detail Activity Report: The grants management 

system can provide a detailed audit of activities of project objectives 

report filtered by PR/Award No. This report displays all project 
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objectives and performances measure information with modification 

details such as Modification Type, Modified By and Modified Date. This 

report is designed to be used by program staff to monitor changes to a 

specific grant’s project objectives.

c. The electronic APR form is automatically placed in the official grant file.

D. Other Pertinent Information

1. The ED 524B is available at the Grant Application and Other Forms table, and 

may be used for both the annual interim and final performance reports.

2. The OMB Form 1894-0017 is available at the Grant Application and Other 

Forms table. 

3. Program offices can access the “help” module in the grants management 

system for information and instructions about creating the ED 524B. 

Additionally, program offices can learn about using the template letters that 

may be used to remind grantees of due dates and submission instructions for 

annual and/or interim ED 524B and program-specific performance reports.

4. For detailed information about OMB Form 1894-0017, see the U.S. 

Department of Education Grant Application Form for Project Objectives and 

Performance Measures Information (OMB Form 1894-0017) – Fact Sheet 

available at: Documents and Forms Referenced in the Handbook for the 

Discretionary Grant Process. 

5. Grantee annual reporting requirements are found at: 2 C.F.R. §§ 200.328 and

200.329 and EDGAR §§ 75.590 and 75.720. 

6.7.6 Research Performance Progress Report

A. Policy

1. The Research Performance Progress Report (RPPR) is used by grantees that 

support research and research-related activities to report research progress 

on an interim and annual basis at the frequency required or designated by the 

program office. 

2. Program offices are not required to implement use of the RPPR if research or 

research-related activities are reported by grantees on a pre-existing OMB 

cleared reporting form.

B. Procedures

1. When requiring the submission of the RPPR, program offices direct recipients 

to complete only those questions, within a component of the RPPR that are 
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relevant to the award or to ED. If a recipient has nothing significant to report 

during the reporting period on a question or item, the instructions state that 

they should note that fact by stating “Nothing to Report” under that question 

or item.

2. Program offices utilize the standard instructions that have been developed for 

each category of the RPPR but may provide additional program-specific 

instructions necessary to clarify a requirement for a particular program.

C. Guidance

1. When program offices deem that the information reported on preexisting OMB 

cleared forms is less detailed and less informative than the information that 

would be submitted on the RPPR, program offices have the flexibility to 

implement the use of the RPPR in lieu of any preexisting OMB cleared 

reporting form. 

a. Program offices should consult with the program official regarding the 

decision to require the submission of the RPPR instead of the submission 

of a preexisting OMB cleared form.

D. Other Pertinent Information – Reserved

6.7.7 Federal Financial Report SF 425 (FFR)

A. Policy

1. Program offices require grantees to submit a Federal Financial Report SF 425 

(FFR) if:

a. Their grants or cooperative agreements involve cost sharing or matching 

and the grantees do not submit the ED 524B, which collects cost sharing 

or matching information (e.g., when program offices require the 

submission of a program-specific performance report approved by OMB 

that does not collect cost sharing or matching information).

b. Program income was earned.

c. The grantee had indirect cost information to report that was not captured 

on the ED 524B, or the ED 524B was not required to be submitted. 

Similarly, if a program office uses a program-specific performance report 

approved by OMB that does not collect indirect cost information, grantees 

using that reporting document must report indirect cost information on the 

FFR. 

d. Program regulations or a specific term or condition require the submission 

of the FFR; 
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e. The grantee submitted a request for a grant reinstatement (see the section 

Processing a Reinstatement).

f. The grantee requests to draw down any of the remaining funds when 

closing out the grant (see the section Grant Closeout - General).

2. Program offices consider the information reported on the FFR to help inform 

decisions about awarding NCC grants.

B. Procedures

1. When the FFR is required, program offices inform grantees of the date when 

the report is due within the first Grant Award Notification (GAN) issued to the 

grantee for the grant project, or under a separate notification as deemed 

appropriate by the program official, or during the post-award performance 

conference, and within subsequent NCC GANs (see GAN Attachment 2, 

Specific Grant Terms and Conditions for Financial and Performance Reports, 

which automatically generates with all new GANs).

2. ED has identified several exceptions related to the reporting of financial data 

on the FFR and related to some of the form’s instructions. Program offices 

take note of these exceptions and communicate them to their grantees when 

requiring the submission of the FFR. See the “Federal Financial Report SF 

425 (FFR) Guidance” document available at Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. 

3. Program offices address concerns over data reported in the FFR with 

grantees prior to awarding NCC grants. Concerns about awarding NCC 

grants based on the information reported are addressed with program officials 

and in situations when a specific condition is to be included with the NCC 

grant, program offices consult with the program attorney prior to imposing the 

specific condition.

C. Guidance – Reserved

D. Other Pertinent Information

1. OMB approved the FFR for the purpose of establishing a standard format 

through which recipients of grants and cooperative agreements may report 

the financial status of their grants and cooperative agreements. Through the 

implementation of the FFR, recipient financial reporting is streamlined across 

Federal government agencies by consolidating, on a single form, financial 

information that recipients of grants and cooperative agreements are required 

to report.
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2. Program offices require the submission of the FFR if a grantee wants to draw 

down funds after the grant project period is over (see the section Grant 

Closeout - General) and for reinstatements.

6.7.8 Substantial Progress

A. Policy

1. Program offices make determinations regarding substantial progress not 

more than 90 days before the end of a grantee’s budget period.

2. Before program offices make an NCC award, the grantee demonstrates that it 

has made substantial progress in achieving the goals and objectives of its 

grant and in meeting its performance measures and targets within the scope 

of its approved grant application (see EDGAR § 75.253(a)(i)).

B. Procedures

1. Prior to making NCC awards, program offices assess the extent to which 

grantees have made substantial progress in achieving the objectives of their 

grant, and in meeting their grants’ performance measures and targets within 

the scope of their approved grant applications, by reviewing and analyzing all 

required performance reports submitted by their grantees (i.e., the ED 524B 

or program specific OMB cleared performance reports, and other required 

reports such as the FFR).

2. Program offices use their documented process for determining the suitability 

and size of the NCC awards and consider the project year. Typically, 

expectations for substantial progress in meeting project objectives should be 

higher toward the end of the approved project period. See the section Making 

Non-Competing Continuation (NCC) Awards. 

3. Program offices ensure that the project data included in the grantees’ annual 

performance and financial reports correspond to the scope and objectives 

that were established in the approved project applications or any approved 

amendments, and that they demonstrate substantial progress.

4. Program offices review the grantees’ responses to the indirect cost questions 

on the ED 524B, and if the indirect cost rate is expired or other concerns arise 

regarding the responses provided, program offices review and follow the 

procedures to address concerns that are found in the Indirect Cost items of 

the section Cost Analysis and Budget Review. 

a. When a reporting form other than the ED 524B is used, program offices 

still verify that the reported indirect cost rate and related information is 

correct and must address any concerns with the grantees arising from the 

review.
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5. Program offices review their grantees’ financial data in the grants 

management system including reviewing fund balance data and the Large 

Available Balance Report (see the section Large Available Balance ).

6. If a grant that is currently being reviewed for substantial progress is listed on 

the Large Available Balance Report, or a review of the grantee’s financial 

data indicates a large balance (but below the threshold for the Large 

Available Balance Report), program offices:

a. Recommend to the program official to either approve the grantee’s plans 

for expenditure of the funds, or recommend a reduction in the amount of 

the new funds to be awarded for the following budget period (see the 

section Carryover and EDGAR § 75.253(c)(1-3)); and

b. Record all discussions, any resolution, and the basis for the resolution in 

the official grant file prior to issuing the NCC award.

7. Program offices, after reviewing both financial and performance data, record 

in the grants management system that the required performance report was 

received, and if it has been determined that substantial progress has been 

made, select substantial progress. These system actions certify that the 

performance report was read, that all financial and performance issues, if any, 

were addressed, and that funds can be obligated for an NCC award.

8. When a grantee is not able to demonstrate that it is making substantial 

progress toward meeting its grant project goals, program offices inform the 

program official and recommend discontinuing funding unless the program 

official approves changes to the project that will enable the grantee to make 

substantial progress in succeeding budget periods (see EDGAR § 75.253 

(a)(2)). In such cases, the grantee submits a plan for approval describing how 

substantial progress will be made in the future to justify continued funding 

prior to the award being made.

9. Approved changes to allow a grantee to achieve the goals and objectives of 

the project and meet the performance targets of the project may not result in 

changes to the scope or objectives of the project. Program offices consult 

with their program attorney when unsure if these approved changes will result 

in changes to scope or objectives.

10.Program offices consult with their program attorney and OPEPD/GPO if a 

decision is made to discontinue funding.

a. A grantee that is denied an NCC is notified in writing, and that notification 

sets out ED’s basis for denying the NCC award.
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b. A grantee that is denied an NCC award under EDGAR § 75.253 may 

object under 2 C.F.R. § 200.341 in the form of a request for 

reconsideration of the decision. The request must:

1) Be submitted in writing to the ED official identified in the notice denying 

the NCC award by a date specified in that notice.

2) Set forth the grantee’s basis for objecting to the decision not to make 

an NCC award and include any relevant supporting documentation.

c. The designated ED official identified in the notice denying the NCC award 

will consider the request for reconsideration and will provide the grantee 

with a written response to that request. That response will be the ED’s 

final decision on the matter.

11.Program offices inform their Budget Service analyst of the decision to 

discontinue funding so that changes to the spending plan, if needed, are 

completed in a timely manner.

C. Guidance

1. In addition to the submission of required reports, and demonstration of 

substantial progress, EDGAR § 75.253 describes what else may be 

considered for a grantee to receive an NCC award. The list below contains 

other components that program offices may consider in an NCC review:

a. Performance – Review APR or other required reports and determine that 

the grantee has made substantial progress in achieving its performance 

targets, goals, and objectives of the approved application.

b. Commitment of Implementation – Program offices monitor the grant 

against the approved application. This is particularly critical in instances 

when the competition included a priority or requirement for projects that 

are supported by evidence of effectiveness. In programs where grantees 

are expected to serve a minimum number of participants, program offices 

ensure grantees have met those requirements.

c. Evaluation – Are grant funds being used to conduct a project evaluation? 

Program offices monitor the progress of that evaluation, including the 

degree to which the grantee is collecting data for that evaluation.

d. Matching – If the grantee is required to contribute matching funds program 

offices monitor the grantee’s progress in securing those funds and 

allocating them to project activities appropriately.

e. Key personnel – If key personnel changes occurred, is the project’s scope 

still implemented as described in the approved application?
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f. Funds – Are funds being carried over from the prior budget period? The 

amount to award the NCC considering the use of funds to date and the 

planned use of the carry over funds.

D. Other Pertinent Information – Reserved

6.7.9 Setting the NCC Award Amount

A. Policy

1. Program offices establish the budget levels for each budget period of a multiyear award when the original award is made. If a cost analysis was not 

initially conducted for the out years of a multi-year award due to an approved 

waiver (see the Applicability section), program offices conduct a cost analysis 

for each of the out years before making an NCC award for each out year. 

Changes in NCC funding levels must not result in a change to the project 

scope or objectives (see the section Prohibiting Changes to the Project Scope 

or Objectives of a Grant).

2. NCC grants are not subject to Congressional notification; thus, program 

offices do not have to adhere to the Congressional notification rules 

referenced in the section Congressional Notification when awarding NCC 

grants.

B. Procedures

1. When NCC amounts established at the time of the original grant awards 

change (e.g., excessive carryover, unallowable costs, etc.), program offices 

review, prior to issuing an NCC award:

a. A grantee’s description of the manner in which the work in the upcoming 

budget period is to be performed and a revised budget and budget 

narrative to reflect the changed NCC amounts, unless the change is to 

reduce funding that was not needed in the previous budget period.

2. If program offices received a waiver to review grantees’ out-year budgets at 

the time of the NCC award, program offices review the upcoming out-year 

budget to ensure cost items are allowable, allocable, and reasonable and 

remove those cost items that do not comply.

3. Program staff review the large available balance report and address any 

potential carry-over in compliance with the Large Available Balance section.

4. Program staff, after review of grantees financial information, determine final 

NCC award amounts.
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5. Program staff establish NCC award amounts 90 days or less before the 

budget period ends.

C. Guidance

1. The grants management system will not automatically issue the standard 

grant award attachments with NCC GANs unless program staff chooses to 

include the grant award attachments. Instead, the NCC GAN references the 

grant award attachments and terms and conditions that were included with 

the initial GAN as being applicable to the NCC award.

D. Other Pertinent Information – Reserved

6.7.10 Carryover

A. Policy

1. Unexpended funds at the end of one budget period can be used in the next 

budget period without any action by ED or the grantee, unless such use of 

unexpended funds is restricted as a condition of the award (see 2 C.F.R. § 

200.308(d) and EDGAR § 75.253(c)(1)).

2. Program offices, when determining the amount of NCC awards, take into 

consideration the amount of unexpended funds, and the reasons the funds 

remain unspent.

B. Procedures

1. Program staff provide good faith efforts (e.g., through TA) early in a budget 

period to assist grantees in resolving excessive balances in order to minimize 

carryover amounts.

2. When program staff discover that an available balance deemed significant by 

the program staff (based on program staff’s understanding of the grantee’s 

performance history) is available for carryover at the time NCC awards are to 

be processed, program staff require a written explanation from the grantee 

that includes the following (see EDGAR § 75.253 (d)(2)):

a. The total amount of the available balance that is already obligated 

(including documentation from the grantee);

b. Any activities that were originally planned for the current budget period but 

were not conducted;

c. The grantee’s anticipated drawdowns during the remainder of the current 

budget period; and
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d. The grantee’s planned use of the funds during the subsequent budget 

period.

3. Program staff consider the grantee’s explanation in deciding how much 

funding to provide for the next budget period.

4. In cases where program staff do not concur with the grantee’s explanation for 

planned expenditures, program staff recommend that the program official 

reduce the NCC amount to be awarded for the following budget period. 

Before making this recommendation, program staff make sure that the 

grantee will have enough funds available to complete the next budget period 

and any activities not completed from the prior budget period.

5. Program staff consult with the program attorney in cases of substantial 

reductions in a grant award but may engage in this consultation regarding any 

reductions.

C. Guidance

1. Program offices should work proactively with grantees to resolve excessive 

funds balance issues as early in the grant year as possible and before NCC 

award decisions are made.

2. To assist with resolving large available balance issues prior to awarding NCC 

grants, program officials may use the optional Consolidated Substantial 

Progress Feed functionality in the grants management system, which is an 

administrative tool that will automatically notify grantees via email of a 

remaining balance if more than 70 percent (default percentage) of the budget 

remains on the last day of the 3rd quarter of the award budget period. If using 

the Consolidated Substantial Progress Feed functionality, program offices 

may change the default percentage by modifying the subprogram record.

3. The email requires the grantee to provide the following to the program office:

a. The total amount of the available balance that is already obligated 

(including documentation from the grantee);

b. Any activities that were originally planned for the current budget period but 

were not conducted;

c. The grantee’s anticipated drawdowns during the remainder of the current 

budget period; and

d. The grantee’s planned use of the funds during the subsequent budget 

period.
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D. Other Pertinent Information - Reserved

6.8 Grant Administration

6.8.1 Grantee Flexibility with Administrative Actions

A. Policy

1. In accordance with EDGAR § 75.264 and 2 C.F.R. § 200.308, grantees are 

not required to seek prior approval for the following categories of 

administrative actions unless restricted by the terms and conditions of the 

award:

a. Budget transfers, unless the transfer requires specific prior approval in 

accordance with 2 C.F.R. § 200.308. 

b. Use of carryover funds for allowable activities or costs that fall within the 

scope and objectives of the project (see the Carryover section for 

additional information related to reviewing carryover amounts).

c. Pre-award costs or expenditures for allowable items and activities of a 

project for a period up to 90 days before the beginning of the new award 

(see EDGAR § 75.263, 2 C.F.R. § 200.308, and the Pre-Award Costs

section for guidance on pre-award cost proposed for periods greater than 

90 days before the beginning of a project period).

d. A one-time no-cost time extension of the final budget period of an award 

for a period of up to 12 months, as authorized in EDGAR § 75.261, unless 

law, regulations, or the grant terms and conditions specify otherwise.

1) 2 C.F.R. § 200.308(d) requires the grantee to notify ED of the intended 

extension at least ten days before the end of the budget period and 

give supporting reasons for the extension.

2) Program offices deny a no-cost extension under 2 C.F.R. § 200.308(d)

if a grantee wants the extension simply to obligate unused funds after 

the objectives of the project have been met.

3) Program offices cannot obligate additional funds to the grant for the 

extension or permit the grantee to conduct activities outside the scope 

and objectives of the approved project. 

4) Grantees can continue to obligate funds during the no-cost extension.
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B. Procedures

1. Grantees are permitted to exercise flexibilities to make post-award 

changes and budget revisions; however, post-award changes must be 

consistent with the project activities and budgets in the approved 

application and must not change the scope or objectives of a competitive 

grant. If program staff has concerns that grant funds are not being 

obligated and expended properly because of any administrative action 

undertaken by a grantee, the program staff asks the grantee to provide 

additional information about the ways in which the grant funds are being 

used.

2. When program staff decides to restrict the flexibility based on review of the 

submitted information, the program staff notifies the grantee of this 

determination, documents the official file and, where appropriate, updates 

the grants management system, and issues a revised GAN.

3. Program offices follow the Restricting Grantee Flexibilities section when 

restricting these flexibilities.

C. Guidance – Reserved

D. Other Pertinent Information- Reserved

6.8.2 Administrative Actions Requiring Prior Approval from ED 

A. Policy

1. Program offices, in accordance with EDGAR and 2 C.F.R. § 200.308, review 

certain types of administrative actions for approval or disapproval before they 

can be implemented by grantees.

2. Administrative actions may be monetary or non-monetary in nature and may 

or may not require prior approval from ED.

3. A Principal Officer, program official or program staff must not authorize any 

administrative actions that conflict with any applicable Federal statute, 

program statute or regulation, EDGAR, 2 C.F.R. Part 200, or specific 

condition. Additionally, changes to a grant are not permitted that alter the 

scope or objectives of a competitive discretionary grant.

4. Some administrative actions require that program staff consult with the 

program official before approving or disapproving a request, and in some 

cases, the program official’s approval or disapproval is required. Refer to the 

table that follows.
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5. Grantees are notified of approvals or disapprovals within 30 calendar days of 

having received requests for administrative actions requiring approval. 

However, if granting approval or disapproving the request is not possible 

within 30 days, then program offices alert the grantee within the 30 calendar 

days that the request is under review and that additional time is needed by 

ED. Program offices also communicate a date by which a decision will be 

made.

B. Procedures

1. Grantees submit a written request to program offices when prior approval for 

administrative actions is required. After receiving a written request for an 

administrative action, program offices may contact grantees directly for 

clarification or for additional information as needed.

2. The decision to approve or disapprove a request for an administrative action 

is based on requirements imposed by applicable Federal statutes, including 

GEPA, program statute and regulations, EDGAR, and 2 C.F.R. Part 200. All 

resulting costs and activities related to approved changes must be allowable 

in accordance with these requirements.

3. If the grantee has been designated as high risk, program staff consult with the 

program official before approving or disapproving a grantee’s request.

4. Program offices are aware that some actions, such as grant transfers, require 

consultation with their program attorney, or other ED staff, before making a 

final decision to approve or disapprove the action.

5. Program offices, in all cases where prior approval is required, keep a copy of 

the grantee’s original request in the official grant file, along with any additional 

information received from the grantee, documentation of discussions with the

program official, program attorney or other ED staff, ED’s written decision 

(including ED’s reason for the action taken), and any amended GAN.

Administrative Action Responsible ED Staff Handbook Reference

Restricting grantee flexibility to take 

administrative action without prior approval 

(Impose Grant Attachment 15).

Program Official Restricting Grantee Flexibility under 

Expanded 

Authorities

Any prior approval requirement established 

by the terms and conditions of the grant (see 

2 C.F.R. § 200.308) 

Program Staff

Evaluating Grant Applicant Risk Prior 

to Making New Grant Awards

Evaluating Risks Prior to Making 

NCC Awards N/A

Pre-award costs incurred more than 90 days 

prior to the budget period. Program Official Pre-Award Costs
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Administrative Action Responsible ED Staff Handbook Reference

Changes in key personnel. Program Staff Changes to Key Personnel

The absence of the project director or 

principal investigator for more than three 

months (see 2 C.F.R. § 200.308). Program Staff Changes to Key Personnel

A 25 percent reduction in the project director 

or principal investigator’s time (see 2 C.F.R.

§ 200.308). Program Staff Changes to Key Personnel

The transfer of substantive work to a third 

party (see 2 C.F.R. § 200.308 and EDGAR § 

75.701).

Program Official N/A

Any other costs that require approval in 

accordance with the 2 C.F.R. part 200 

subpart E, “Cost Principles.”

Program Staff N/A

Revising grantee cost sharing or matching.

Program Official 

License Holder

After consulting with program 

attorney

Revising Grantee Cost 

Sharing

The need for additional funds (supplemental 

grant awards).

Program Official 

License Holder Supplemental Awards

Transfer of funds into Indirect Costs (see 

EDGAR § 75.560(d) Program Official Indirect Costs

The transfer of a grant from one entity to 

another or a change in legal status. License Holder Grant Transfers

Second grant extension requests EDGAR 

§ 75.261 © Program Staff Extension of the Final Budget 

Period

All other grant extension requests after the 

second request, including those submitted 

after the project end date and those 

requesting an extension beyond 12 months.

Program Official Extension of the Final Budget 

Period

UEI number changes, other than grant 

transfers, and technical changes Program Staff

C. Guidance

1. When considering requests for administrative actions, program offices can 

review the table above for guidance. The sections referenced under the 

column titled “Handbook References” identifies sections in the Handbook that 

provide detailed information about the administrative actions listed in the 

chart, and these sections should be reviewed by programs when considering 

requests. The column titled “Responsible ED Staff” identifies the position that 
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is required to respond to the administrative request with an approval or 

disapproval.

2. Program staff should encourage their grantees to submit administrative

requests to modify their active grants through the grants management 

system. The following are advantages for doing so:

a. Upon receipt of these requests, they are automatically saved in the 

database and are immediately available to ED staff for approval or 

disapproval.

b. The grants management system sends emails to the grantees confirming 

receipt of the requests. The system also sends an email to the appropriate 

ED program staff notifying them that an administrative request has been 

received.

c. The administrative approval and GAN, if applicable, is automatically filed 

in the grantees electronic grant file.

3. When program offices receive inquiries from other ED offices related to a 

grantee’s administrative actions, the inquiries should be considered urgent 

and a timely response should be provided, so that awards, administrative 

actions or other performance and compliance matters are addressed quickly 

and appropriately.

D. Other Pertinent Information – Reserved

6.8.3 Grantees’ Technical Changes that Do Not Require Prior 

Approval

A. Policy

1. Many changes are made to a grant that do not require ED’s prior approval. 

Nevertheless, grantees document all changes in their files, and inform their 

ED program contacts of the changes, as some of these changes require 

action by ED to be effective.

2. Technical changes that do not require prior approval include business 

address changes, telephone number changes, new email addresses, and UEI 

changes when they involve correcting a UEI resulting from a data entry error.

3. Program staff do not make UEI changes when the grantee’s UEI registration 

in SAM is inactive. Programs will receive an error message in the grants

management system at the time of the change and immediately contact the 

grantee for resolution.
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B. Procedures

1. Program offices receive requests for technical changes through the grants 

management system or in writing from the grantee’s project director or other 

authorized official.

2. Program offices enter a grantee’s technical change in the grants management 

system (e.g., when the change involves business address changes, 

telephone number changes, new email addresses, and UEI changes that 

correct a UEI that resulted from a data entry error), sign and issue an updated 

GAN and include an updated GAN in the official grant file without further 

approval.

C. Guidance – Reserved

D. Other Pertinent Information - Reserved

6.8.4 Restricting Grantee Flexibilities under 2 C.F.R. § 200.308

A. Policy

1. To restrict one or all the flexibilities authorized under 2 C.F.R. § 200.308, 

program offices complete and include with the GAN, Grant Attachment 15, 

“Prior Approval Requirements.”

B. Procedures

1. When program officials deem it appropriate to restrict or rescind the 

flexibilities for a grant or group of grants after new or NCC awards have been 

issued, they do so only after consultation with their program attorney. 

a. Removing the grantee’s authority to exercise flexibilities may be 

implemented as a specific award condition with or without designating the 

grantee high risk.

C. Guidance

1. Program offices should establish a procedure for determining when the use of 

Grant Attachment 15 is appropriate for a grant program. A common reason 

for disallowing flexibilities involves making the terms of one or more grant 

awards conform to statutory or regulatory requirements, that conflict with the 

expanded authorities, for a grant program or a category of grantee. 

Additionally, circumstances (e.g., poor fiscal management) may arise for 

which a grantee should not be allowed to exercise the flexibilities to make 

changes and budget revisions as permitted under 2 C.F.R. § 200.308(d). 
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D. Other Pertinent Information

1. The grants management system is the official repository for GAN attachments 

and enclosures. For information purposes only, the grant attachments and 

enclosures are also available on ConnectED at the following link: Grant 

Award Notification (GAN) Attachments for Discretionary Grants. 

6.8.5 Changes to Key Personnel

A. Policy

1. Program offices, after an award is issued, approve, or disapprove requests for 

changes to key personnel and sign and issue a revised GAN.

B. Procedures

1. Program offices, before approving changes to key personnel, consider the 

requirements in 2 C.F.R. § 200.308(c) regarding changes in key personnel.

2. Program offices approve or disapprove grantees’ requests for:

a. The initial hiring of a person to fill a position described in an application 

when no one was named, or no resume was provided;

b. Changing persons who occupy key positions that were identified in the 

application; or

c. Substantively redefining a key position and its duties.

3. Program offices, to maintain current and accurate information on key 

personnel, enter the names, titles, percentage of time, and other required 

information into the key personnel tab of the discretionary budget sub-function 

in the grants management system whenever key personnel changes occur 

during the life of a project.

4. Program offices verify in SAM that the key persons identified are not included 

in the SAM Exclusions list.

5. Program offices contact their GMPD liaison if the key person is included in the 

SAM Exclusions list before proceeding with the request for the personnel 

change. 

a. The GMPD liaison verifies whether the key person identified is the same 

person appearing in the SAM Exclusions list. To conduct this verification, 

program offices provide the individual’s resume, last 4 digits of the social 

security number, current and last known address, and current and last 

known employment.
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b. GMPD investigates the reasons why the person is included in the SAM 

Exclusions list and advises the program staff of any issues that would 

prevent the person from participating on the grant.

c. Program offices, based upon the information provided and the advice of 

GMPD, consults with their program official, and their program attorney, if 

necessary, to establish next steps.

6. Program offices document all discussions, ED’s written decision (including 

ED’s reason for the action), and the amended GAN in the official grant file.

C. Guidance

1. Guidance regarding who may be defined as key personnel is provided in the 

section Key Personnel – Qualifications Review & Excluded Parties List.

D. Other Pertinent Information – Reserved

6.8.6 Revising Grantee Cost Sharing or Matching

A. Policy

1. Program offices specify on the GAN the total cost sharing or matching, 

including the required or voluntarily committed amounts or percentages, if the 

grantee:

a. Is required by statute or regulation to provide an amount or percentage of 

cost sharing or matching;

b. Voluntarily commits to provide additional cost sharing or matching above 

what is required; or

c. Voluntarily commits to cost sharing or matching where none is required.

2. The combination of Federal funds and the value of the grantee’s cost sharing 

or matching contribution equal the total cost of the grant (see 2 C.F.R. § 

200.306 and the section Calculating Cost Sharing or Matching Amounts). 

3. Notwithstanding exceptions in Procedures item 2, grantees are required to 

fulfill their cost sharing or matching commitment, both required and 

volunteered, since they are a condition of the award.

a. A grantee may request to reduce voluntary cost sharing or matching; 

however, program offices do not approve requested reductions when the 

reductions impact the scope and objectives of the grant. Program offices 

consult with their program attorneys when assistance in making these 

determinations is needed.
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4. The minimum dollar amount or percentage of cost sharing or matching the 

grantee is required to pay is specified in the relevant statute or program 

regulation.

B. Procedures

1. Program offices make every effort to work with the grantee to help the 

grantee find ways to meet the cost sharing or matching requirements in the 

event a grantee raises concerns about its ability to contribute the required or 

voluntarily committed dollar amount specified on the GAN, especially since 

the amount of cost sharing or matching proposed in the grantee’s application 

could have been a significant or decisive factor for reviewers who recommend 

funding the project.

2. If the grantee is unable to provide a cost sharing or matching dollar amount, 

even after program office intervention, the program official may permit 

reductions to the amount of the Federal award after consultation with the 

program attorney, Budget Service, OPEPD/GPO, and with approval from OS.

3. The reduction by the program official cannot change the scope or objectives 

of the original application or reduce the amount of cost sharing or matching 

below a statutory or regulatory minimum. In the case where the reduction in 

cost sharing or matching alters the scope and objectives of the project, that 

reduction would indicate an impact on the competitiveness of the application 

and would not be permissible for that reason. If a reduction can be made 

without violating these restrictions, the program official may take one or more 

of the following actions:

a. If the statute, regulation, or application notice establishes a maximum 

percentage for the Federal share of project costs, the program official may 

reduce the amount of Federal funds awarded so that the maximum 

Federal percentage share of total costs is not exceeded; or

b. The program official may waive all or part of the established level of cost 

sharing or matching if: a) the program statute or regulations permit 

changes to cost sharing or matching percentages or amounts, and the 

program official has consulted with their program attorney; or b) the cost 

sharing or matching was volunteered by the grantee; or

c. If the grantee had voluntarily committed cost sharing or matching at a level 

exceeding that required by statute or regulation and ED made the 

voluntary contribution a condition of the grant award, the program official 

may reduce the Federal grant in proportion to the amount of reduction 

made to the grantee’s share of the costs down to its legally required 

minimum.
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d. Review section Waiving Required Cost Sharing or Matching for additional 

policy and guidance on this topic.

1) The license holder issues a revised GAN updating the terms and 

conditions of the award, if the program official takes one of the actions 

described in item 2.

2) The program official consults with their program attorney to decide on 

appropriate courses of action when a change in the scope of the 

project is likely to occur because of the reductions to cost sharing or 

matching.

3) All actions taken by the program official are documented in the official 

grant file.

C. Guidance – Reserved

D. Other Pertinent Information – Reserved

6.8.7 Prohibiting Changes to the Project Scope or Objectives of a 

Grant

A. Policy

1. ED program officials have the authority in accordance with 2 C.F.R. § 

200.308 to review and approve requests from grantees to change the scope 

or objectives of their discretionary grants; however, to ensure the integrity of 

ED’s competitive review process, ED does not permit changes to the scope or 

objectives of a grant except in rare cases where the grant was awarded 

without competition or other highly unusual circumstances.

B. Procedures

1. If a grantee requests a change to its grant and the change might involve a 

change in the scope or objectives of the grant, before approving or 

disapproving the request, program offices consult with their program attorney 

to get assistance in determining whether the change will constitute a change 

in the scope or objectives of the grant and, if so, whether the change would 

deny basic fairness to other applicants that participated in the original grant 

competition.

2. The program official notifies the grantee in writing of the status of its request, 

whether it is approved, approved in part, or not approved within 30 days of 

receipt. If approved in part, a final determination is made within 90 days of 

receipt. A copy of the written approval or disapproval of the request is placed 

in the grantee’s official grant file.
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C. Guidance

1. ED defines scope as the nature and extent of the work performed under a 

grant. Depending upon the objectives of the grant project, scope may include 

the number, nature and timing of the activities, and participants or subjects of 

the grant. Objectives are defined as the goals and strategic purpose of the 

grant or cooperative agreement, as described in the grant application.

D. Other Pertinent Information – Reserved

6.8.8 Data Collection Period – EDGAR § 75.250(b)

A. Policy

1. Program officials have the authority to approve a data collection period for a 

grant for the sole purpose of collecting, analyzing, and reporting performance 

measurement data regarding the project.

2. In accordance with EDGAR § 75.250(b), program officials inform applicants of 

their intent to approve data collection periods in the NIA published for a 

competition or may decide to fund data collection periods after grantees have 

started their project periods.

3. Program officials ensure that funds are not obligated for data collection 

activities that will extend more than five years beyond the Federal period of 

availability (e.g., funds obligated in September 2019 for a data collection 

period that extends from October 1, 2019 through September 30, 2025). In 

such instances, funds revert to Treasury before the end of the data collection 

period. Program offices address the issue in the example by obligating funds 

from multiple years to support the full data collection period.

4. Program officials include, as part of a grant program’s spending plan, the 

scheduling and funding information for data collection awards.

B. Procedures

1. Program offices consult with their program attorney, after the determination to 

make data collection period grants, regarding the review and award selection 

processes since these will differ from a regular grant competition.

2. Program offices document the review and award processes and include the 

required information in the New Slate Memo Template. 

C. Guidance

1. Program officials should determine which grant programs would benefit from 

extension periods for data collection purposes. Program officials should 
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consider how an extension period for data collection, analysis, and reporting 

would improve knowledge about the program and specific projects funded by 

the program. 

a. For example, if the data needed to determine a project’s effectiveness will 

not be available by the end of the grantee’s performance period, the 

program official may determine that awarding an extension to that grantee 

is the best option to ensure that ED and the field can learn from the 

project.

2. The data collection extension period award process should be as informal as 

possible while still maintaining basic fairness. The process may differ if the 

NIA informed applicants of the possibility of a data collection extension period 

versus when program officials decide to offer data collection periods after 

grantees have already been collecting data.

3. If grant program funds are made available for data collection purposes, 

programs should carry out a fair and transparent process to award the funds. 

The phases presented in the Funding for Data Collection Purposes (available 

at Documents and Forms Referenced in the Handbook for the Discretionary 

Grant Process) document, loosely aligned to the grant award phases, 

provides general activities as well as some common questions that may be 

considered to assist with carrying out a fair and transparent funding process.

4. Program officials should ensure that funds made available for data collection 

periods do not exceed the minimum amount necessary to accomplish the 

purposes of the extension. If such data collection periods are funded 

incrementally, programs take all necessary steps to reduce carryover 

balances, including the reduction of NCC awards as necessary.

D. Other Pertinent Information

1. Program offices include the information required for this funding option in the 

Grant Funding Slate in accordance with the Grant Funding Slate instructions.
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6.9 Publications

A. Policy

1. Grantees, in carrying out their grants, may plan to publish a variety of 

materials. If the program has reason to believe that a grantee is going to 

produce these kinds of materials as part of the grant activities, program 

offices notify the grantee of the requirement to include in any such materials 

the disclaimer in EDGAR § 75.620 that states:

The contents of this (insert type of publication; such as book, report, film) 

were developed under a grant from the Department of Education. However, 

those contents do not necessarily represent the policy of the Department of 

Education, and you should not assume endorsement by the Federal 

government.

2. When grantees wish to use ED’s official seal on materials they produce, 

approval is provided by OCO. For approval to access and use the seal, 

program offices or their grantees contact the OCO.

B. Procedures – Reserved

C. Guidance - Reserved

D. Other Pertinent Information

1. Contact information regarding approval to use ED’s seal is available at: ED’s 

Official Seal. 

6.10 Open Licensing Requirements

A. Policy

1. For competitive grants awarded in competitions announced after February 21, 

2017, ED requires, with certain exceptions, that entities receiving ED 

competitive grant funding open license all grant deliverables created wholly or 

in part with those funds and that constitute a new copyrightable work. For 

purposes of the open licensing requirement, grant deliverables are 

considered the final version of a work, including any program support 

materials that are necessary to appropriately use the deliverables (see 2 

C.F.R. § 3474.20).

2. When grant deliverables consist of modifications to pre-existing works, the 

open license extends only to those modifications that can be separately 

identified and only to the extent that the open license is permissible under the 

terms of any licenses or other legal restrictions on the use of pre-existing 

works. 
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3. Exceptions to the open licensing requirement include the following:

a. Grant programs that provide funding for general operating expenses;

b. Grant programs that provide support to individuals (e.g., scholarships, 

fellowships);

c. Grant deliverables that are jointly funded by ED and another Federal 

agency if the other Federal agency does not require open licensing of its 

grant deliverables for the relevant grant program;

d. Copyrightable works created by the grantee or subgrantee not using ED 

grant funds;

e. Peer-reviewed scholarly publications that arise from any scientific 

research funded, either fully or partially, from grants awarded by ED (for 

example, publications subject to IES’ public access plan);

f. Grantees or subgrantees under the Ready to Learn Television Program;

g. A grantee or subgrantee that has received an exception from the 

Secretary under 2 C.F.R. § 3474.5 and 2 C.F.R. § 200.102; and

h. Grantees or subgrantees for which compliance with the open licensing 

requirement would conflict with, or materially undermine the ability to 

protect or enforce, other intellectual property rights or obligations of the 

grantee or subgrantee.

4. The regulation at 2 C.F.R. § 3474.20 requires that ED grantees or 

subgrantees that are subject to the open licensing requirement grant to the 

public a worldwide, non-exclusive, royalty-free, perpetual, and irrevocable 

license to access, reproduce, publicly perform, publicly display, and distribute 

the deliverable; prepare derivative works30 and reproduce, publicly perform, 

publicly display and distribute those derivative works; and otherwise use the 

deliverable, provided that proper attribution is given.

5. Grantees and subgrantees have the flexibility to select open licenses 

appropriate to their grant deliverables that comply with the requirements of 2 

C.F.R. § 3474.20. The open licenses must also contain a visible symbol 

communicating the permissions granted concerning the use of the grant 

deliverable, machine- readable code for digital resources, readily accessed 

30 For the purposes of the open licensing regulations, “derivative work” is defined in the Copyright Act (17 

U.S.C.§ 101) as “a work based upon one or more preexisting works, such as a translation, musical 

arrangement, dramatization, fictionalization, motion picture version, sound recording, art reproduction, 

abridgment, condensation, or any other form in which a work may be recast, transformed, or adapted. A 

work consisting of editorial revisions, annotations, elaborations, or other modifications which, as a whole, 

represent an original work of authorship, is a “derivative work.”
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legal terms, and the statement of attribution and disclaimer specified in 

EDGAR § 75.620 (b). 

6. The regulation at 2 C.F.R. § 3474.20 also requires that ED grantees and 

subgrantees have a plan to disseminate the openly licensed grant 

deliverables.

B. Procedures

1. Program offices inform applicants of the open licensing requirements in the 

grant competition’s NIA in accordance with Chapter J of the RQM and ED’s 

Common Instructions and remind their grantees of the open licensing 

requirements throughout the grantees’ grant performance periods.

C. Guidance

1. In the past, grantees have open licensed grant deliverables using the General 

Public License (GPL) for computer code and Creative Commons licenses for 

educational resources.

D. Other Pertinent Information – Reserved

6.11 Supplemental Awards

A. Policy

1. As a matter of policy, supplemental awards should be avoided whenever 

possible, as it is ED’s goal to maximize the number of new awards to promote 

innovation in education consistent with the priorities of the Secretary and the 

Administration.

2. Program officials do not award supplemental funds to a grantee unless they 

have determined it would be impractical to award such funds on a competitive 

basis to accomplish the same purposes.

3. The New Funding Slate Memo Template is required to recommend funding 

for supplements, and it is routed from the originating office’s Principal Officer 

through the Executive Secretariat to the Office of the Secretary (OS) for 

approval.

4. Program offices award supplements only after the Secretary has approved 

the Funding Slates.

5. Program officials will consult with their program attorney and submit a strong 

justification and plan as part of their New Funding Slate Memo Template that 

demonstrates the need to supplement a grant or grants.
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6. Program offices do not obligate funds for a supplemental award when a 

grantee’s UEI registration in SAM is inactive. Programs will receive an error 

message in the grants management system at the time of obligation and 

immediately contact the grantee for resolution. Program staff only use the 

pre-award exempt functionality (see the section UEI Registrations Reviews in 

SAM – Pre-Obligation) for those situations where a genuine exigency, such 

as the clear potential that funds will lapse if funds are not awarded 

immediately, is present when awarding NCCs.

B. Procedures

1. Program officials document a plan to make supplement awards:

a. In the program’s spending plan approved by the Budget Service (with the 

concurrence of their program attorney, OPEPD/GPO, and OS); and

b. In the program’s New Slate Memo Template approved by OS.

2. The documented plan to supplement awards includes a description of:

a. The purpose of the proposed supplements;

b. The grantees that will be considered for the supplemental award, the 

rationale for determining which grantees will be considered; or

c. How the opportunity for the supplemental awards will be communicated to 

the grantee(s);

d. How required information from grantees will be collected (e.g., revised 

budgets, how the funds will be used, and a description of the activities 

being supplemented);

e. How award determinations will be made (e.g., the criteria and process for 

the determinations); and

f. An assurance that the proposed supplemental awards will not change the 

scope or objectives of the existing grants.

3. If the supplement is awarded at the request of the grantee, the program 

requires the grantee to provide a written justification demonstrating why the 

supplement is necessary. If the supplement is based on the program needs of 

ED, the program provides a written justification demonstrating why the 

supplement(s) is (are) necessary. In either case, the justification is included in 

the official file for the affected grant, or in the original competition file if a 

group of grants is affected.
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4. If the plan for supplemental awards is approved, program offices obtain from 

each grantee a revised budget indicating how the funds will be used and a 

description of the activities being supplemented.

5. Program offices conduct risk evaluations for supplements and consider:

a. The amount of time that has passed since the last risk evaluation;

b. Whether risk issues were previously identified, and risk mitigation 

strategies implemented;

c. The grantee’s progress in addressing the risk issues identified; and

d. Any applicable information garnered from the relationship established 

between the grantee and program.

6. Program offices, when conducting a risk evaluation, consider prior and/or 

current financial and performance information, compliance with Federal audit 

requirements, audit findings, progress in achieving corrective actions set in 

place to resolve audit findings, compliance findings, and other administrative 

issues. Additionally, programs consider any issues or concerns, identified 

through day-to- day oversight, routine monitoring, and TA efforts, that might 

adversely affect a grantee’s performance.

7. If risks are identified that require specific award conditions, a program, after 

consultation with the program attorney, may impose a specific award 

condition in accordance with 2 C.F.R. § 200.208, or designate the specific 

conditions as “high- risk” conditions, and designate the grantee or grant high 

risk in accordance with 2 C.F.R. § 3474.10. 

8. Program offices review and consider information about grantees in FAPIIS if 

the grants exceed or will exceed, over the course of the discretionary grant 

project periods, the simplified acquisition threshold. This review is conducted 

before making supplement awards that exceed the simplified acquisition 

threshold. Currently, this threshold is $250,000.

9. Before awarding a supplement, program offices, at a minimum, determine 

that the information in FAPIIS: 1) demonstrates a satisfactory record of 

executing programs or activities under Federal grants, cooperative 

agreements, and procurement awards; and 2) demonstrates integrity and 

good business ethics (see 2 C.F.R. § 200.206).

C. Guidance

1. Program offices should identify situations where they may need to 

recommend making supplemental awards as soon as possible in the grant-
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making process, and they should alert Budget Service and their program 

attorney to the circumstances as soon as possible.

2. Decisions to make supplemental awards are subject to policy considerations, 

so program offices should start by getting approval for making supplemental 

awards from their Assistant Secretary. Then, program offices, in consultation 

with Budget Service, should secure approval from OPEPD/GPO and OS prior 

to making supplemental awards. A proposal to make a supplemental award 

should be documented in the program’s spending plan.

3. Program officials should note that merely describing a supplemental award 

plan within a spending plan, and/or New Funding Slate Memo does not 

guarantee approval of that proposal. Program offices should consult with their 

Budget Service analyst and their program attorney as soon as possible when 

considering supplemental awards; Budget Service and the program attorney 

will help program offices determine whether the circumstances are 

appropriate for making supplemental awards and guide the program offices 

through the review of their plan by OPEPD/GPO and OS.

4. The following scenarios are examples of situations in which supplemental 

awards may be appropriate:

a. One or more grants in a program was not fully funded in a prior year due 

to insufficient funds available at the time of award. In this case, the 

program official submits a justification for approval to supplement the grant 

or grants to provide up to 100 percent funding of allowable costs.

b. Program offices may wish to use funds from one program to supplement 

one or more grants made under another program as an efficient strategy 

for supporting a policy goal (e.g., adding funds to an existing technical 

assistance center to serve grantees rather than funding an entirely new 

center).

c. A program official sees an opportunity under an ED program to 

supplement grants to carry out activities consistent with the Secretary’s 

Supplemental Priorities, so long as the supplemented grants still have the 

same scope or objectives.

d. A grantee runs into unexpected costs in performing the grant and requests 

an increase in support. Generally, the program official may supplement 

the grant if funds are available, and the funds are used for activities within 

the scope and objectives of the initial award. Shortfalls arising from 

mismanagement or inefficient use of funds do not create adequate 

justification for supplements.

e. A grantee develops a new line of research growing out of the original 

research or develops a new method for conducting its research. 
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Generally, the program official would not be able to supplement the award, 

because the grantee won the competition based on the method proposed 

in the application and for the objectives of the original line of research. 

However, in some cases where the additional research is very small in 

comparison to the overall scope of the grant, a supplement might be 

acceptable.

f. An ED program learns about a grant funded by another program of ED, or 

funded by another Federal agency, and wants to give the grantee funds to 

pursue an interest relevant to the ED non-funding office. These types of

supplements may, or may not, be appropriate depending upon whether 

the supplement would have the effect of changing the scope or objectives 

of an ED grant.

g. Another agency meets an ED grantee and sees an opportunity to fund 

more work by the grantee in the same or similar areas to the work already 

being conducted by the grantee, and the other agency desires to transfer 

funds to ED so that ED may award these funds as a supplement to the 

grantee. Generally, these situations are resolved based on the law

applicable to the other agency’s funds.

h. A program official sees an opportunity under an ED program to 

supplement grants to carry out activities that support and enhance general 

program activities as provided in the program statute or regulations. This 

type of supplement is not allowable in instances where there is a single 

grantee under a program. This general supplement to all the grants under 

a program may be acceptable if the supplemented grants still have the 

same scope or objectives.

5. If ED has entered into a joint funding agreement with another Federal agency 

under GEPA section 430, or another joint funding authority, and one of the 

agencies wants to supplement a joint-funded project, the determination to 

supplement will depend upon the nature of the joint funding agreement 

between the agencies and the identity of the agency managing the grant.

6. While EDGAR states that ED only funds up to 100 percent of the allowable 

costs of a grant when an award is made (EDGAR § 75.233 (a)), a supplement 

that raises the funding level above the 100 percent cap may be deemed 

appropriate by the program official in consultation with their program attorney 

and Budget Service; however, the supplement must not change the scope or 

objectives of the grant.

7. A program official that wishes to use unobligated funds to supplement grants 

from a current appropriation at the end of the fiscal year, does not 

automatically assume that grants may be supplemented with those funds 

simply because they remain unspent at the end of the fiscal year. Rather, 
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grants may be supplemented at that time if the supplements meet the 

requirements of this Policy section.

D. Other Pertinent Information

1. Program offices use the New Funding Slate Template for supplemental 

awards. The template provides prescriptive guidance pertinent to supplement 

funding, and it goes through Executive Secretariat clearance before approval 

by the Secretary. The template memo for the Grant Funding Slate is available 

at the following link: New Funding Slate Memo Template. 

2. For requirements in regulations addressing SAM registrations, see 2 C.F.R. 

Part 25. 

6.12 Grant Transfers

A. Policy

1. When circumstances arise that do not permit a grantee to carry on the work 

for which their grant was awarded, program offices determine whether it is 

appropriate to terminate the grant or transfer the remaining work and grant 

funds to another eligible organization.

2. When the preferred course of action is to transfer a grant, both the current 

and future grantee must agree to the transfer.

3. A grant transfer is executed when the transfer involves a change in the legal 

recipient and all other aspects of the grant are not changed.

4. A grant transfer cannot take place when it involves an award to an individual. 

Additionally, a grant cannot be transferred to or between foreign institutions or 

international organizations.

5. Although the circumstances that make a grant transfer necessary can vary 

widely, a grant transfer is executed for the following reasons:

a. Change in eligibility, identity, or legal status. Some changes in grantee 

status (such as the loss of eligibility to participate in ED programs) 

eliminate a grantee’s legal authority to carry out one or more objectives of 

the project. Other changes in grantee status are of a legal or formal nature 

and do not materially affect a grantee’s performance of the project (such 

as the merger of two institutions, or an institutional name change resulting 

in a new UEI Number).

1) A grant transfer is not required for an organization that only changes its 

name. In these cases, the name change should be recorded in the

grants management system. Before making a UEI number change, 
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however, program offices take extra care to verify with the grantee that 

a name change does not reflect an actual change in the legal identity 

or status of the grantee entity.

2) The following, although not all inclusive, are examples of when a UEI 

number change requires a grant transfer:

a) A university is requesting to change the grant UEI number from the 

university’s UEI number to that of a non-profit housed at the 

university, and the grant will be implemented and administered by 

the non-profit.

b) An organization in one State is requesting a UEI number change to 

that of a newly established office for the same organization in 

another State, and the grant will be implemented and administered 

in the new office.

b. Movement of key personnel. Some grants are awarded to eligible 

entities that function only as “nominal” or “accommodation” grantees. 

Although they are the grantees of record, their sole function is to sponsor 

the participation of certain key individuals whose work is the sum and 

substance of the project. If such a key person moves to another eligible 

entity, a grant transfer may be made if all the other conditions for a 

transfer are met.

c. Other circumstances that render the grantee unable to carry out the 

project. For a variety of reasons (such as major restructuring, loss of 

resources, impending bankruptcy), a grantee may lose their ability to 

honor their commitment to finish the work of a project. Under these 

circumstances, there may be conditions that warrant transfer of the grant 

to another eligible entity to: 1) complete the project; and 2) ensure that the 

grant’s intended beneficiaries are served.

6. A transfer agreement is completed by all parties involved in the transfer (i.e., 

the transferor [ED’s original grantee] and the transferee [the replacement 

grantee]). A template of the transfer agreement titled “Grant Transfer 

Agreement” is available at the following link: Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. 

7. Program staff do not obligate funds for a Transferee when the Transferee’s 

UEI registration in SAM is inactive. Programs will receive an error message in 

the grants management system at the time of obligation and immediately 

contact the Transferee for resolution. Program staff only use the pre-award 

exempt functionality (see the section UEI Registrations Reviews in SAM – 

Pre-Obligation) for those situations where a genuine exigency, such as the 
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clear potential that funds will lapse if funds are not awarded immediately, is 

present when transferring a grant.

B. Procedures

1. Program offices follow the procedures in the document titled “Grant Transfer 

Procedures” when transferring a grant, which is available on ConnectED at 

the following link: Documents and Forms Referenced in the Handbook for the 

Discretionary Grant Process. 

2. Before approving a grant transfer, the license holder consults with the 

program attorney to address any legal concerns to ensure that:

a. The transfer does not circumvent or appear to circumvent the ED 

competitive grant process;

b. The need for the project or activity that existed at the time of original 

award still exists;

c. The terms and conditions of the transfer are acceptable to both the 

original grantee and the new organization;

d. The new organization meets all standards of eligibility for the grant 

program;

e. The new organization agrees to carry out future activities as specified in 

the original application and, if possible, keep the same key personnel to 

manage the grant as were identified in the original grant;

f. The new organization will continue to serve the same population with the 

same level of service as the original grantee;

g. The change is made in a timely manner; and

h. No increase in funding over the original amount of the award is required.

3. Prior to finalizing a grant transfer, program offices review and consider 

information about the transferee in FAPIIS if the grant exceeds or will exceed, 

over the course of the discretionary grant project period, the simplified 

acquisition threshold set by the Federal Acquisition Regulations (FAR) at 48 

C.F.R. Subpart 2.1. Currently, this threshold is $250,000.

2. FAPIIS reviews for grant transferees are conducted in accordance with the 

policy in section FAPIIS Information Review Requirements. 
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C. Guidance

1. Generally, a grant transfer is a voluntary action initiated by the grantee due to 

a circumstance which impacts its ability to continue and complete the work for 

which the funds were awarded.

D. Other Pertinent Information

1. For requirements in regulations addressing SAM registrations, see 2 C.F.R. 

Part 25. 

6.13 Extensions of the Final Budget Period

6.13.1 One-Time Extensions Authorized in EDGAR § 75.261(a)

A. Policy

1. Grantees may initiate a one-time no-cost extension, without prior approval, as 

authorized in EDGAR 75.261(a) in accordance with the following:

a. Grantees may request to initiate a one-time extension of the final budget 

period without the obligation of additional funds by the Federal 

government (i.e., a no- cost extension), unless explicitly prohibited by the 

program statues and/or regulations or a condition of the award; and

b. Grantees notify ED in writing with the supporting reasons for the one-time 

no- cost extension, and the revised expiration date at least ten days 

before the project period end date; however, ED may waive the ten day 

notification requirement on a case-by-case basis in accordance with 

EDGAR § 75.261 (a) if the extension is otherwise appropriate.

c. In identifying a revised expiration date, the grantee must identify the actual 

time (months) needed to complete the work.

2. While the grantee may initiate the notification for an extension without prior 

approval, the no cost extension is not automatic and is reviewed in 

accordance with this section.

3. Program staff review their grantees’ notifications to extend the final budget 

period of a grant in accordance with the procedures in this section to 

determine if the notifications justify the need for the extension.

4. The one-time no-cost extension is only permitted for a period of up to 12 

months, but the 12 months is not automatic, and the actual extension period 

proposed should match the actual work to be completed and the amount of 

funds remaining unspent under the grant.
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5. One-time no-cost extensions merely for the purpose of using unobligated 

balances, when all grant project activities have been completed, are 

prohibited in accordance with 2 C.F.R. § 200.308(d)(2). 

6. For grants that receive funding for an entire 60-month grant period in their 

initial grant award (i.e., frontloaded grants), extensions may not be feasible 

because this unspent funding will revert to the United States Treasury five 

years after the end of the fiscal year in which the funds were obligated.31

However, if any such grant is awarded supplement funding after the first year, 

an extension that meets the requirements under EDGAR § 75.261 may be 

initiated for amounts awarded under the supplement to accomplish activities 

authorized by the supplement. Activities supported under the initial grant 

award may not be continued during the no-cost extension.

7. Grantees may not submit notifications for one-time no-cost extensions when 

prohibited from doing so in the applicable grant program’s statute or 

regulations. Additionally, grantees may not submit notifications for one-time 

no-cost time extensions when program offices have explicitly prohibited onetime no-cost time extensions by restricting the administrative flexibility (see 

the section Restricting Grantee Flexibilities), or through a specific condition or 

high-risk designation due to performance and/or financial management 

issues. 

8. Grantees may incur new obligations during a no-cost extension of the project 

period.

B. Procedures

1. When a grantee submits a notification of a one-time no-cost extension, 

program offices review the grantee’s plan for using the remaining funds to 

determine:

a. If the proposed use of the funds is within the scope and objectives of the 

grant;

b. That the grantee’s plan does not suggest management problems with the 

project or the grantee entity;

c. That the additional time period proposed in the notification is proportionate 

to the amount of funds remaining and the activities to be undertaken (e.g., 

a grant having a few thousand dollars remaining unspent at the end of the 

31 For example, if a grantee receives a fully frontloaded 60-month award on September 30, 2018, the 

funds revert to treasury at the same time the project ends. However, if a grantee receives a fully 

frontloaded 60 month award at any other time during the fiscal year, the grantee could receive a one-time 

no-cost extension through the end of the fifth fiscal year of the grant (e.g., if the grantee received its 

frontloaded award on June 1, 2018, it would complete its project on May 31, 2023, and would have 

several months before the end of the fiscal year in which the funds revert to Treasury).
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project period would probably not justify an entire 12-month extension 

period); and

d. That the grantee is not exercising the one-time no-cost extension merely 

for the purpose of using unobligated balances when all grant project 

activities have been completed.

2. Program offices, in reviewing the grantee’s reasons for a one-time no-cost 

extension, also review the grantee’s financial data to:

a. Ensure that the remaining funds are enough for the activities that the 

grantee proposes to complete;

b. Determine whether the grantee has appeared on the Large Available 

Balance report (see the section Large Available Balance). Program offices 

review documentation of the large available balances included in the 

official grant file.

c. Determine if the funds that will be used during the extension period are 

still within the 5-year timeframe of expiration. Program staff deny 

extension requests that would extend beyond the 5-year period of 

availability of funds.

3. When program offices have concerns regarding the notification received for a 

one- time no-cost extension, they contact the grantee to address the 

concerns and resolve any issues before extending the grant.

4. Program offices, if accepting the grantee’s reasons in its notification for a onetime no-cost extension:

a. Amend the data field in the grants management system to show the new 

project period end date;

b. Issue a copy of an amended GAN to the grantee; and

c. Include a copy of the amended GAN in the official grant file along with the 

grantee’s notification and supporting reasons for the extension.

5. When program offices have justifiable reasons for not accepting the grantee’s 

explanation about why funds remain unspent, or their intended use of those 

funds during the proposed extension period, or they cannot resolve questions 

arising about the remaining fund balances for the grant, program offices may 

deny the one-time no-cost extension. Program offices immediately notify the 

grantee in writing with reasons for the denial and places a copy of this 

response in the official grant file.
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a. If the liquidation period has not expired for the grant and the one-time nocost extension is denied, program offices place the grantee on cost 

reimbursement to ensure that any funds drawn down during the liquidation 

period are used solely for the purpose of closing out the grant.

6. If a grantee sends a one-time no-cost extension notification to program staff 

after the project period end date, the program staff forwards the request to the 

appropriate program official along with a recommendation for either accepting 

or rejecting the extension. After the program official issues, a decision, the 

program staff places a record of the decision and any supporting 

documentation in the official grant file.

C. Guidance

1. Program offices should expect that grantees will complete all grant activities 

during the one-time no-cost extension and should convey this expectation to 

their grantees so that incomplete work under their grants may be diligently 

completed and to minimize the need for additional time beyond the one-time 

no-cost extension.

2. Program offices should, in their monitoring efforts throughout their grantees’ 

performance periods, familiarize themselves with any late start-ups, 

personnel changes, delays in achieving objects, targets and measures, and 

large available balances, so that they may proactively work with grantees 

(e.g., through appropriate TA) to aid them in successfully completing their 

grant projects within their established project periods. This knowledge will 

also enable program offices to address legitimate needs for one-time no-cost 

extensions by providing guidance to grantees during the final budget period 

(i.e., usually during the last quarter of the final budget period) about what 

should be addressed in their notifications.

D. Other Pertinent Information – Reserved

6.13.2 One-Time No-Cost Extensions Exceeding 12 Months

A. Policy

1. One-time no-cost extensions exceeding 12 months do not fall within the 

scope of 2 C.F.R. § 200.308(d)(2); thus, they must be considered under 

EDGAR § 75.261 © and (d). In these cases, the grantee submits a request 

for prior approval at least 45 calendar days before the end of the project 

period in accordance with EDGAR § 75.261 ©(4)(b), unless a waiver of the 45 

calendar day requirement has been issued under EDGAR § 75.261 (d) that 

justifies the need for the additional time, provides updated timelines with 

completion dates, lists remaining activities to be completed, and identifies 

unobligated funds.
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2. One-time no-cost extensions merely for the purpose of using unobligated 

balances, when all grant project activities have been completed, are 

prohibited in accordance with 2 C.F.R. § 200.308(d)(2). 

3. For grants that receive funding for an entire 60-month project period in their 

initial grant award (i.e., front loaded grants), extensions may not be feasible, 

since this unspent funding will revert to the United States Treasury five years 

after the end of the fiscal year in which the funds were obligated. However, if 

any such grant is awarded supplemental funding after the first year, an 

extension that meets the requirements under EDGAR § 75.261 may be 

initiated for amounts awarded under the supplement solely for the purpose of 

completing activities authorized under the supplement.

4. Program officials may not approve one-time no-cost extensions that exceed 

12 months when prohibited from doing so in the applicable grant program’s 

statute or regulations. Additionally, program officials may not approve onetime no-cost extensions when program staff have explicitly prohibited onetime no-cost extensions by restricting flexibilities (see the section Restricting 

Grantee Flexibilities ), or through a specific condition or high-risk designation 

due to performance and/or financial management issues.

B. Procedures

1. Program offices review the requests for approval to determine:

a. If the proposed use of the funds is within the scope and objectives of the 

grant;

b. That the extension does not suggest management problems with the 

project or the grantee entity;

c. That the additional time period proposed in the notification is proportionate 

to the amount of funds remaining and the activities to be undertaken (e.g., 

program staff may determine that there are not enough funds to cover the 

entire extension period requested, and may decide that a lesser period of 

time better correlates to the actual work to be completed and the amount 

of funds remaining unspent);

d. That the grantee will not be exercising the one-time no-cost extension 

merely for the purpose of using unobligated balances, when all grant 

project activities have been completed; and

e. Determine if the funds that will be used during the extension period are 

still within the 5-year timeframe of expiration. Program staff deny 

extension requests that would extend beyond the 5-year period of 

availability of funds.
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2. Program offices also review the grantee’s financial data in the grants

management system to:

a. Ensure that the remaining funds are enough for the activities that the 

grantee proposes to complete; and

b. Determine whether the grantee has appeared on the Large Available 

Balance report. Program offices review documentation of the large 

available balances included in the official grant file.

3. Program offices, after the review is complete, forward the request for 

extension to the appropriate program official along with a recommendation to 

approve or disapprove the extension.

4. When program offices have justifiable reasons for not accepting the grantee’s 

explanation about why funds remain unspent, or their intended use of those 

funds during the proposed extension period, or they cannot resolve questions 

arising about the remaining fund balances for the grant, program offices may 

recommend that the program official disapprove the one-time no-cost 

extension. Program offices immediately notifies the grantee in writing of the 

disapproval and place a copy in the official grant file.

a. If the liquidation period has not expired for the grant and the one-time nocost extension request is disapproved, program offices may place the 

grantee on cost reimbursement to ensure that any funds drawn down 

during the liquidation period are used solely for the purpose of closing out 

the grant.

5. If the program official approves the request for a no-cost extension exceeding 

12 months, program offices:

a. Amend the data field in the grants management system to show the new 

project period end date;

b. Issue the grantee a copy of an amended GAN showing the new end date 

along with the program official’s approval; and

c. Include a copy of the amended GAN in the official grant file along with the 

grantee’s no-cost extension request, program official’s approval, and any 

other supporting documentation.

6. If a grantee sends a one-time no-cost extension notification to program staff 

after the project period end date, the program staff forwards the request to the

appropriate program official along with a recommendation for either accepting 

or rejecting the extension. After the program official issues, a decision, the 

program places a record of the decision and any supporting documentation in 

the official grant file.
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C. Guidance

1. For applicable guidance, see the section One-Time Extensions Authorized in 

EDGAR § 75.261 (a). 

D. Other Pertinent Information – Reserved

6.13.3 Subsequent No-Cost Extensions

A. Policy

1. After grantees have initiated a one-time no-cost extension, and they find they 

need additional time beyond the original extension period, they submit a 

request for prior approval. 

2. No-cost extensions beyond the one-time no-cost extensions authorized under 

EDGAR § 75.261 (a) do not fall within the scope of 2 C.F.R. § 200.308(d)(2); 

thus, they are considered under EDGAR § 75.261 (c) & (d). For these nocost extensions, the grantee submits a request for prior approval at least 45 

calendar days before the end of the project period in accordance with EDGAR 

§ 75.261 (c)(4)(b), unless a waiver of the 45 calendar day requirement has 

been issued under EDGAR § 75.261 (d), that justifies the need for the 

additional time, provides updated timelines with completion dates, lists 

remaining activities to be completed and identifies unobligated funds.

3. No-cost extensions falling under this section that are needed merely for the 

purpose of using unobligated balances, when all grant project activities have 

been completed, are prohibited in accordance with 2 C.F.R. § 200.308(d)(2). 

4. Program officials may not approve no-cost extensions that fall under this 

section when no-cost extensions are prohibited in the applicable grant 

program’s statute or regulations. Additionally, program officials may not 

approve no-cost extensions that fall under this section when program staff 

have explicitly prohibited one-time no-cost extensions by restricting this 

flexibility, or through a specific condition or high-risk designation due to 

performance and/or financial management issues.

B. Procedures

1. Program offices follow the procedures under the section One-Time No-Cost 

Extensions Exceeding 12 Months because these procedures are also 

applicable to the no-cost extensions that fall under this section.
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C. Guidance - Reserved

D. Other Pertinent Information – Reserved

6.14 Grant Performance – Addressing Risk and Other Issues

6.14.1 Enforcement

A. Policy

1. Program offices minimize grantee performance, management, or financial 

management issues or risks by engaging grantees on a regular basis through 

formal and continuous monitoring or TA efforts.

2. Program offices resolve grantee performance, management, or financial 

management issues or risks when monitoring or TA efforts prove insufficient 

by: 

a. Imposing specific award conditions;

b. Designating a grant high risk when previously imposed specific award 

conditions do not result in resolution;

c. Designating a grantee high risk when previously imposed specific award 

conditions do not result in resolution and the risk factors are systemic or 

they adversely impact internal controls, and the risk factors adversely 

impact all grants ED awarded/will award to the grantee;

d. Voluntary Termination of a project by the grantee;

e. Denying a grantee an NCC award (see the section Making NCC Awards);

f. Withholding, for GEPA programs, or Suspension and Termination for nonGEPA programs.

1) For GEPA programs, generally all programs not authorized by the 

HEA, withholding funds under the procedures set out in Part D of 

GEPA when all previous efforts to have grantees resolve issues and 

risks fail; and, the possibility of denying an NCC award is not available.

2) For non-GEPA programs, generally those authorized by the HEA, 

suspension and termination of a grant under 2 C.F.R. §§ 200.339

through 200.341 when all previous efforts to have grantees resolve 

issues and risk fail.

g. Other legally appropriate remedies.
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3. As a general matter, program offices follow policy items 1 and 2 as a 

progression towards more elevated enforcement efforts when monitoring and 

TA are deemed insufficient. However, program offices may impose specific 

award conditions, designate a grant or grantee high risk, or initiate 

withholding of funds at any point after following appropriate procedures. This 

can be done even if less elevated approaches have not been used if the 

performance, management, financial management issues, or risks are severe 

enough to justify immediately taking any of these actions.

4. Program staff align monitoring and TA efforts to track: 1) a grant or grantee’s 

resolution of identified issues and risks; 2) the effectiveness of specific 

conditions; or 3) the effectiveness of a high-risk designation.

B. Procedures

1. Post Award Conference, Continuous Monitoring and TA

a. Program staff address performance, management, or financial issues or 

risks identified during the grant application review, budget cost analysis, or 

by peer reviewers during the post award performance conference (see the 

section Post Award Conference). If the issues or risks identified require 

assistance beyond that provided during the post award conference, 

program staff establish a schedule to provide continuous monitoring and 

TA to mitigate the issues and risks.

b. Program staff regularly evaluate their monitoring and TA efforts to assess 

if they are resulting in improvements, no changes, or if the issues and 

risks are escalating despite the program office’s monitoring and TA efforts. 

This evaluation may lead to changes in monitoring and TA efforts, or if 

deemed appropriate, efforts to mitigate issues and risks may be escalated 

by imposing specific conditions and/or high-risk designations in 

accordance with Policy item 2.

c. TA provided during post award conferences, schedules for providing 

ongoing monitoring and TA, evaluation of the program office’s monitoring 

and TA efforts in response to identified issues and risks, and the results of 

the continuous monitoring and TA efforts are documented in the official 

grant file (see the section The Official Grant File).

2. Specific Award Conditions

a. Program staff immediately alert the program official when routine 

monitoring or TA efforts are unsuccessful in mitigating risk to determine, in 

consultation with their program attorney, whether specific award 

conditions should be imposed on the grant or grantee.
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b. Program staff, after consultation with their program attorney, impose 

specific conditions that address risk factors and may include the following 

when a grant or grantee: 1) has a history of noncompliance; 2) fails to 

meet its expected performance goals and objectives; or 3) is not otherwise 

responsible (see 2 C.F.R. § 200.208).

1) Requiring payments as reimbursements rather than advance 

payments;

2) Withholding authority to proceed to the next phase until receipt of 

evidence of acceptable performance within a given period of 

performance;

3) Requiring additional, more detailed financial reports;

4) Requiring additional project monitoring;

5) Requiring the non-Federal entity to obtain technical or management 

assistance;

6) Establishing additional prior approvals; or

7) Requiring an action by the grantee that targets the nature and severity 

of the risk factor.

3. High Risk

a. Program staff immediately alert the program official when routine 

monitoring, TA efforts, or specific conditions are unsuccessful in mitigating 

risk to determine, in consultation with their program attorney, whether a 

grant or grantee should be designated high-risk. 

b. Program officials designate a grant or request that RMSD designate a 

grantee as high risk in accordance with 2 C.F.R. § 200.208 and 3474.10

accordingly:

1) Prior to making the decision to designate a grant (i.e., a grant project) 

as high risk (item b addresses designating a grantee entity high risk), 

program officials collaborate with program staff and the program 

attorney to determine that the high-risk designation is the appropriate 

course of action to be taken.

2) In addition to designating a grant high risk, program officials may 

request that the OAGRM Deputy Assistant Secretary designate a 

grantee entity (i.e., the grant and all ED grant projects associated with 

the entity under the entity’s UEI) high risk in accordance with 2 C.F.R. 

§§ 200.208 and 3474.10, but consult with their program attorney and 
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their RMSD State lead prior to the OAGRM Deputy Assistant 

Secretary’s designation. RMSD is responsible for managing grantee 

level high-risk designations, facilitating consultation with all program 

offices that award grants to the grantee entity and their program 

attorneys, and ensuring implementation of the high-risk designation of 

an entity across ED. The facilitated consultation with all program 

offices that award grants to the grantee, and their program attorneys, 

provides all principal offices that have made grants to the entity the 

opportunity to weigh in on the proposed high-risk decision.

3) Once a determination has been made to designate a grant or grantee 

high risk, the associated specific condition is automatically considered 

high risk.

4. Voluntary Termination

a. A grantee may also request to voluntarily terminate its grant in whole or in 

part (see 2 C.F.R. § 200.339(a)(4)) when it decides that it cannot 

implement the grant as required under the program statute, regulations of 

ED, and the conditions in the grant award, including any specific 

conditions.

5. GEPA Withholding (programs covered by GEPA)

a. ED may, under Part D of GEPA, initiate proceedings to withhold grant 

funds from a grantee if it concludes that the grantee has substantially 

failed to comply with an applicable legal requirement.

6. Suspension and Termination (programs not covered by GEPA)

a. Program staff immediately alert the program official to determine, in 

consultation with their program attorney, whether a grant or grantee 

should be suspended or terminated.

b. Program officials suspend or terminate a grant in accordance with 2 

C.F.R. § 200.339 accordingly:

1) Program officials act to suspend or terminate a grant only under 

egregious circumstances (e.g., previous action taken by ED has not 

resulted in resolution of a problem or risk; a grant, grantee, or an 

employee of the grant has been debarred or suspended; or there is 

evidence of illegal conduct), and consult with their program attorney to 

determine if suspension or termination actions are appropriate.

2) Program officials, after consultation with their program attorney, 

suspend or terminate a grant awarded under the HEA by using 
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procedures specified under the section Required Notification to 

Grantees that follows.

C. Guidance

1. Program staff may document and track grant issues, audit findings, corrective 

actions, missing documents, etc., in PAM, and this information is available for 

access in PAM by other program staff across ED. When a grant has an issue 

and that grant’s UEI is associated with other grants, program staff responsible 

for those other grants may view the information available in PAM to determine 

if their grant has the same issue, or a similar issue, or has the potential for 

that same or similar issue to occur.

2. While not required to contact RMSD when designating a grant (i.e., a grant 

project) high risk, program officials may consult with RMSD to discuss specific 

conditions and to determine if designating the grant high risk is appropriate.

3. Risk mitigation decisions should be made in conjunction with considerations 

of the severity of the risk, any repetition of the risk, the relevance of the risk to 

a specific program, any prior enforcement or assistance efforts and success 

of those efforts, and any prior sanctions imposed.

4. Selection of the appropriate specific condition(s) is based on the particulars of 

the risk factor and how it affects both the grant and/or grantee, and the 

resources of the program staff to monitor the conditions.

5. Prior to imposing specific conditions, program staff should contact the ARD to 

determine the status of any outstanding findings or program determination 

letters (PDLs) issued by ED offices, including the status of any corrective 

actions.

D. Other Pertinent Information

1. RMSD issues high-risk specific conditions to grantees that are applicable to 

all grants made to the grantees and provides these high-risk specific 

conditions with applicable instructions to program offices. For information 

about these grantees and the applicable high-risk specific conditions, 

program staff may contact their RMSD State Leads available at the following 

link: RMSD State Leads. 

2. ED’s Risk Mitigation Guide provides mitigation strategies for different areas of 

grant and grantee risks, and it is available as resource to program offices at: 

ED Risk Mitigation Guide. 

3. ED’s Risk Rubric Guide is available to assist program offices in developing a 

tool to evaluate grantee risk, and to inform decision making about NCC 
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awards and monitoring activities. The Risk Rubric Guide is available at: Risk 

Rubric Guide. 

6.14.2 Required Notification to Grantees

A. Policy

1. Program offices notify grantees when imposing specific conditions and when 

designating a grant or grantee high risk. (see 2 C.F.R. § 200.208 and EDGAR 

§ 75.235).

B. Procedures

1. Specific Conditions

a. If the decision was made, after consulting with the program attorney, to 

impose on an award specific condition(s) that address additional 

requirement(s) or action(s) by a grantee, program offices notify the 

grantee of:

1) The nature of the additional requirements;

2) The reason why the additional requirements are being imposed;

3) The nature of the action needed to remove the additional 

requirements, if applicable;

4) The time allowed for completing the actions, if applicable, and

5) The method for requesting reconsideration of the additional 

requirements imposed.

b. The specific conditions imposed are included in the award by amending 

the GAN to include the specific conditions, and the GAN is issued to the 

grantee.

c. If the specific condition added to the amended GAN does not include the 

items listed in number 1 above, the program includes a cover letter with 

the GAN to the grantee that addresses these items and issues that new 

GAN and cover letter to the grantee. A copy of the amended GAN and the 

cover letter is included in the official grant file.

d. Once program offices have determined that a specific condition has been 

satisfied, or the issues or risks that led to the specific condition have been 

resolved, program offices remove the specific condition, generates a new 

GAN without the specific condition, includes a GAN cover letter explaining 

that the specific condition has been removed from the award, and issues 
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that new GAN and cover letter to the grantee. A copy of the amended 

GAN and cover letter is included in the official grant file.

e. If program offices have determined that a specific condition has lessened, 

but not resolved the risk, program offices may decide to revise the specific 

condition to be less burdensome for the grant and/or grantee, by revising 

the GAN to reflect a new or amended specific condition, and issues that 

new GAN to the grantee. A copy of the amended GAN is included in the 

official grant file.

2. High Risk

a. High-risk designation and related high-risk specific conditions are included 

on the GAN, or addressed in a separate cover letter that is crossreferenced on the GAN (see 2 C.F.R. §§ 200.208 and 3474.10).

b. The GAN and/or cover letter address the following:

1) The nature of the additional requirements;

2) The reason why the additional requirements are being imposed;

3) The nature of the action needed to remove the additional 

requirements, if applicable;

4) The time allowed for completing the actions, if applicable, and

5) The method for requesting reconsideration of the additional 

requirements imposed.

c. Once a grant or a grantee entity is designated high risk, the program official 

or his/her designee forwards a copy of all the correspondence related to 

the program official’s decision to RMSD for input into the Risk Module in 

the grants management system. 

1) The information in the Risk Module is then available to all ED principal 

offices for their consideration when monitoring their grants and when 

making new or NCC awards to a grantee or applicant that has been 

designated high risk or has a current grant award that has been 

designated high risk. See the section Risk Module. 

3. Voluntary Suspension or Termination

a. Program staff inform a grantee to send a letter to the program official 

addressing the following when a grantee decides to voluntarily terminate 

its grant, because it is unable to perform the work of the grant:
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1) The reasons for the termination;

2) The effective date of the termination; and

3) In the case of a partial termination, the portion of the grant to be 

terminated.

b. In the case of partial terminations:

1) If the grantee requests a partial termination, the program official 

determines whether funding the remaining portion of the grant will 

change the scope or objectives of the grant.

2) If the partial termination does not change the scope and objectives of 

the grant, the program official amends the GAN to reflect the partial 

termination.

3) If partial termination would result in a change to the scope or objectives 

of the grant, the program official obtains consent from the grantee for 

other changes that do not affect the scope or objectives of the grant 

and amends the GAN to reflect any agreed upon changes.

4) If the program official cannot get a grantee to consent to appropriate 

changes that do not change the scope or objectives of the grant, the 

program official informs the grantee in writing that they must either:

a) Agree to terminate the entire grant; or

b) Continue performance of the grant as specified under the statute, 

regulations and conditions of the GAN or as proposed by the 

program official.

c. All pertinent documentation related to voluntary suspensions and 

terminations are filed in the official grant file (i.e., the letter that explains 

the reason for the termination, and communications that discussed the 

termination or partial termination).

d. Both ED and the grantee remain responsible for grant closeout in 

compliance with the requirements in 2 C.F.R. § 200.344. 

4. Withholding under GEPA Programs

a. Program officials notify a grantee before withholding funds. The notice 

shall state: 1) the intent to withhold funds; 2) the factual and legal basis for 

ED’s conclusion that the grantee has failed to comply substantially with a 

requirement of law; and 3) the opportunity for a hearing at least 30 days 

after the notification has been sent to the grantee before the OALJ.
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b. Pending the outcome of the withholding hearing before the OALJ, ED may 

suspend payments to a grantee, suspend the authority of the grantee to 

obligate funds, or both, after the grantee has been given reasonable 

notice and an opportunity to show cause why future payments or authority 

to obligate grant funds should not be suspended.

c. Program officials, before initiating proceedings to withhold funds, consult 

with their program attorney.

5. Suspension and Termination for Cause for non-GEPA Programs

a. Program officials notify a grantee that they are terminating its grant in 

accordance with 2 C.F.R.§ 200.339. Additionally, program offices inform 

the grantees that: 1) ED will report the termination in FAPIIS, and this 

information will remain available in FAPIIS for five years from the date of 

the termination notification (see 2 C.F.R. § 200.213) ; 2) the grantee has 

the right to review the information in FAPIIS and provide comments in 

FAPIIS on any information that FAPIIS contains about the grantee; and 3) 

ED will consider the grantee’s comments when determining if the grantee 

is qualified for future grant funding. See 2 C.F.R. § 200.340 and the 

section FAPIIS Information Review Requirements. 

b. If program offices terminate a grant based on the grantee’s material failure 

to comply with the requirements of the grant, programs notify the GMPD

FAPIIS Reporting Point of Contact, and the contact will provide 

information to FAPIIS about the termination. Program offices forward to 

the GMPD FAPIIS Reporting Point of Contact a copy of the notification 

sent to the grantee and any available supporting documentation. The 

notification and any supporting documentation are forwarded to the GMPD

FAPIIS Reporting Point of Contact within 48 hours after the notification 

has been issued.

c. The program official follows the procedures below to suspend or terminate 

a grant for cause:

d. The program official sends the grantee a notice including:

1) The reasons for the suspension or termination;

2) The effective date of the suspension or termination;

3) A note indicating the grantee’s right to appeal the suspension or 

termination to the Principal Officer;

4) The address where the appeal must be sent;

5) The date by which the grantee must submit their appeal;
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6) That the Principal Officer reaches a decision on the appeal and notifies 

the grantee of the decision within a reasonable period, as specified in 

the notice; and

7) Other information required under 2 C.F.R. § 200.340, including that the 

determination to terminate a grant has been entered into FAPIIS, that 

the information will remain in FAPIIS for five years from the date of the 

determination (see 2 C.F.R. § 200.213), that the grantee has the right 

to review the information in FAPIIS and provide comments in FAPIIS 

on any information that FAPIIS contains about the grantee, and that 

ED will consider the grantee’s comments when determining if the 

grantee is qualified for future grant funding.

e. Program offices forward to the GMPD FAPIIS Reporting Point of Contact a 

copy of the termination notification sent to the grantee and any available 

supporting documentation, and the contact will provide information to 

FAPIIS about the termination. The notification and any supporting 

documentation are forwarded to the GMPD FAPIIS Reporting Point of 

Contact within 48 hours after the notification has been issued.

f. All pertinent documentation related to suspensions and terminations is 

filed in the official grant file.

g. Program offices consult with their program attorney before initiating a 

suspension and termination of a grant.

C. Guidance – Reserved

D. Other Pertinent Information

1. The GMPD FAPIIS Reporting Point of Contact can be found at the following 

link: GMPD FAPIIS Reporting Point of Contact . 

6.15 Risk Module

A. Policy

1. The Risk Module in the grants management system is the official central 

repository for all information related to grants or grantees designated high 

risk, and all high-risk designations are maintained in this module.

B. Procedures

1. Programs access the risk module when:
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a. An email alert message is sent to the program contact from the RMSD 

that indicates a grant or grantee has been designated high risk and the 

information is contained in the risk module;

b. Making a new or NCC award and an alert is displayed on the budget tab 

page; and

c. A problem arises with a grant during a budget period.

2. If programs receive a high-risk alert message, they access the risk module 

and assess the information. In this assessment, program staff:

a. Review the information in the module;

b. Ask the principal office that assigned the high-risk status for updates, if 

any;

c. Inform their program official and program attorney of the high-risk status 

and provide them with the documentation from the module; and

d. If only a grant was designated high risk, determine whether a grant they 

administer also should be monitored and/or designated high-risk, or any 

other actions that should be taken with regard to a new grant or NCC 

award being considered for funding.

e. If a grantee was designated high risk the program official requires the 

license holder to issue a revised GAN establishing the same terms and 

conditions that ED is applying to all of the entity’s grants.

f. Certify in the Risk Module that the assessment is completed.

3. New or NCC Award: If program officials are considering a new award for 

funding, and the risk module indicates that a UEI has been associated with a

grantee whose entire organization has been designated high risk, the 

program officials should impose the same specific conditions or actions as 

those identified in the risk module on the new award being considered for 

funding. The program official may also consider additional specific conditions 

or actions from the list in the section Grant Performance – Addressing Risk 

and Other Issues, as necessary, to address specific high-risk concerns not 

covered with a grant in the risk module.

The program official is not required to use the same specific conditions or 

actions if the entire grantee organization is not high risk and, in consultation 

with their program attorney, may choose any item from the list in the section 

Grant Performance – Addressing Risk and Other Issues as appropriate to that 

particular grant.
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C. Guidance

1. The data in the risk module is available to all POCs and allows them to be 

consistent in their treatment of grants awarded to organizations that have 

been designated high risk, and that receive multiple grant awards from ED. 

The risk module contains:

a. Identifying information about the high-risk grant or grantee along with the 

name of an ED contact involved in the high-risk designation;

b. The high-risk designation letter and all other correspondence from or to 

the grantee about the high-risk designation and related high-risk specific 

conditions; and

c. The high-risk specific conditions or actions imposed as part of the 

designation and identified on the GAN.

2. The grants management system uses the UEI to search for matches in the 

high-risk database. If a UEI number is associated with a grant or grantee that 

has been designated high risk, at the time of entering or reviewing budget 

data for a new or NCC award, the system generates an alert for all grant 

applications and grants with the same UEI number. The system also alerts 

programs when processing a UEI number change or a grant transfer.

D. Other Pertinent Information – Reserved

6.16 Grant Closeout – General

A. Policy 

1. Grantees must submit, no later than 120 calendar days after the end date of 

their period of performance, all financial, performance, and other reports as 

required by the terms and conditions of the grant. 

2. Program offices may approve extensions when requested and justified. 

3. Unless Program offices authorize an extension (see section B.6.a. in Grant 

Closeout Processes), grantees must liquidate all financial obligations incurred 

under the grant no later than 120 calendar days after the end date of the 

period of performance as specified in the terms and conditions of the grant.

4. Grantees must promptly refund any balances of unobligated cash that ED 

paid in advance or paid and that are not authorized to be retained by the 

grantees for use in other projects. See 2 C.F.R. § 200.346, Part D of the 

General Education Provisions Act, and EDGAR part 81 for requirements 

regarding unreturned amounts that become delinquent debts.
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5. Program offices will complete closeout actions no later than one year after the 

end of the period of performance unless otherwise directed by authorizing 

statutes or regulations.

6. If grantees do not submit all reports in accordance with the terms and 

conditions of the grant, program offices will proceed to close out the grant

with the information available within one year of the period of performance 

end date.

7. If grantees do not submit all reports within one year of the period of 

performance end date, in accordance with 2 C.F.R. § 200.344, ED will report 

the grantee’s material failure to comply with the terms and conditions of the 

award to FAPIIS, and may pursue other enforcement actions in accordance 

with 2 C.F.R. § 200.339. 

8. Program offices retain and dispose of all grant files in accordance with ACSDOCIO-013, Records Retention and Disposition Schedules on the ConnectED 

Information Management website at: General Records Schedules. 

B. Procedures 

1. Program offices complete the following necessary steps to close out a grant:

a. Review the final performance report and determine whether the grantee 

achieved the scope and objectives of the grant; and

b. Determine if all applicable administrative actions and financial obligations 

have been completed by the grantee and that the grant is ready for 

closeout. 

2. Program offices complete the “Closeout Checklist for Discretionary Grants” 

available on ConnectED at the following link: Documents and Forms 

Referenced in the Handbook for the Discretionary Grant Process. The 

checklist requires the signature of the program staff person who closed the 

grant and the signature of the license holder if funds were de-obligated.

3. Program offices receive a monthly closeout report, with more frequent reports 

sent near the end of the fiscal year, which identifies grants in manual closeout 

status due to missing reports or remaining funds. Program offices obtain the 

missing reports and/or verify the remaining funds following the procedures in 

the section Grant Closeout Processes. 

C. Guidance

1. The grants management system will automatically close out a grant when:

a. The project period has ended;
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b. All the required reports have been received and found to be satisfactory; 

and

c. There are zero funds available in the grant account.

D. Other Pertinent Information

1. Subrecipients must submit to the grantee, no later than 90 calendar days (or 

an earlier date as agreed upon by the grantee and its subrecipients) after the 

end date of the period of performance, all financial, performance, and other 

reports as required by the terms and conditions of the Federal award and 

subaward.

a. Grantees with respect to their subrecipients, may approve extensions 

when requested and justified.

b. Subrecipients must liquidate all financial obligations incurred under the 

subaward no later than 90 calendar days after the end date of the period 

of performance as specified in the terms and conditions of the subaward.

c. Subrecipients must promptly refund any balances of unobligated cash that 

the grantees, with respect to subrecipients, paid in advance or paid and 

that are not authorized to be retained by the subrecipient for use in other 

projects. See 2 C.F.R. § 200.346, Part D of the General Education 

Provisions Act, and EDGAR part 81 for requirements regarding unreturned 

amounts that become delinquent debts.

2. For expired grant files maintained in hard copy, program offices only transfer 

these files to the Federal Records Center (FRC) when on-site storage is not 

available.

6.16.1 Grant Closeout Processes

A. Policy

1. Program offices monitor their grants through the grants management system

closeout statuses, and close out grants expeditiously following the procedures 

listed in the section.

2. Closeout statuses in the grants management system. At the end of a 

grant’s project period, the grant moves to one of four closeout statuses. The 

four statuses and their associated activities that programs monitor are listed 

below. The system automatically assigns the “Closed” status to grants where 

all the reports have been received and logged, the remaining balance is zero 

and the grant has been in suspension for more than 30 days.
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a. Liquidation. The liquidation status is the first closeout phase in the 

grants management system and occurs immediately after the grant’s 

performance period has ended. In the liquidation status, a grantee is 

given 120 calendar days from the end of the grant’s performance period to 

submit final performance and financial reports and draw down funds for 

obligations incurred prior to their grant’s performance period end date. No 

action is required by programs. The 120 calendar-day mark is ED’s 

standard.

b. Suspension. The suspension status is the second closeout phase in the 

system provides an additional 5-month period following the liquidation 

period to complete grant closeout activities. A grant in the suspension 

status has either unexpended funds remaining, or a required report was 

not received and recorded in the system or both. While in this status, a 

grantee may make online adjustments to their grant’s financial data. 

However, the grantee may not draw down any funds remaining in the 

grant account without the program office’s approval and intervention. The 

5-month period is ED’s standard.

c. Manual closeout. At the end of the 5-month suspension status period, if a 

grant still has either unexpended funds or a required report was not 

received and recorded by program staff, the grants management system

automatically moves the grant to a manual closeout status. While in the 

manual closeout status, program offices contact the grantee regarding the 

unexpended funds or missing report(s) and resolves any issues 

preventing the grant from being closed.

d. Closed. A grant in the closed status indicates that the grant’s project 

period has ended, all required reports have been submitted, and the 

remaining balance is zero (for information about closing a grant with funds 

remaining unspent, see item #4 in the Procedures section, Closing a grant 

with fund balances below).

3. Program officials monitor the close out process within their program areas to 

ensure that all grants eligible for closeout are being closed without 

unnecessary delays.

4. Program officials will complete closeout actions no later than one year after 

the end of the period of performance unless otherwise directed by authorizing 

statutes or regulations.

B. Procedures

1. Program offices, to close out the grant, initiate and perform the following 

actions:
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a. Pre-expiration letter. Issue a Pre-Expiration Reminder Letter to grantees at 

least 60 calendar days prior to their performance period end date. This 

letter reminds grantees of their reporting responsibilities once the grant 

ends. The letter details the grantee’s financial obligation to draw down 

funds for outstanding obligations during the liquidation period. It also 

reminds grantees that if they fail to comply with the terms and conditions 

of the award, both performance and financial, the grant may be closed in 

noncompliance.

b. Required reports. Request and review the final performance report and 

Federal Financial Report (FFR), if an FFR is required, to determine if the 

grant is ready to be closed or needs to remain open for further post-award 

action. Record the receipt of the final performance report(s) in the grants 

management system. In accordance with EDGAR § 75.590, all recipients 

are required to submit a final performance report.

1) Final Performance Report: Program offices review the final 

performance report to ensure that the grantee has achieved the grant’s 

objectives and makes a note in the official grant file that the report was 

read and acceptable as submitted. If any information in it is unclear, 

program offices contact the grantee for clarification. Program offices 

contact the grantee if the report has not been received or if the final 

performance report failed to communicate or substantiate that the 

goals of the grant were achieved, program offices follow-up with the 

grantee to determine whether an oversight occurred, or if the recipient 

truly failed to meet the grant’s objectives.

a) If efforts to resolve these issues are unsuccessful, program offices 

close the grant in noncompliance (see item #5 below, Closing a 

grant in noncompliance).

2. Federal Financial Report (FFR): Some recipients are required to submit an 

FFR. A final FFR is required if the grant involved cost sharing or matching 

and the ED 524B was not used, program income was earned under the grant, 

or program regulations or a specific condition require it. 

a. An FFR is also required if a grantee wants to draw down funds after the 

grant period is over (see item #4 below, Closing a grant with fund 

balances) or for a closed grant that needs to be reinstated.

1) If the FFR is required, program offices use the following steps to 

determine total expenditures, cost sharing or matching requirements, 

and indirect costs, if applicable. When following these steps, if there 

are differences between what the grantee reports on the FFR and the 

data in the grants management system, program office contact the 

grantee to determine the cause of the difference.
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2) Compare the total Federal share reported on the FFR to the 

performance period total in block 6 of the GAN and the balance in the

grants management system. Review the payee information screen. 

The award status should indicate that the award is in one of the four 

closeout statuses defined in the Policy section. The amounts in the 

completed payments field should equal the Federal share reported by 

the recipient on the FFR and the amount indicated on the GAN under 

block 7, performance period. If any of the amounts under completed 

payments or Federal share reported are less than what is reported on 

the GAN under block 7, performance period, then program offices 

follow up to determine the basis for the discrepancy. Additional followup, if necessary, may include a review of the grantee’s payment history 

in the grants management system. 

3) Compare the total amount of the recipient share required, as reported 

on the FFR, to the cost sharing or matching amount shown in the 

approved budget. Block 7 of the GAN indicates the required cost 

sharing or matching stated as a percentage or an amount of funds 

identified by the grantee in their application under the heading nonFederal funds.

4) Compare the indirect cost rate shown in block 11b and 11d of the FFR

to the approved rate.

5) Inform the grantee that acceptance of final reports does not constitute 

approval of all activities under the grant and that the grant is subject to 

further review and audit. This information is communicated in the 

“Notification of Closeout Letter.”

3. Closing a grant with zero balance of funds remaining. Complete the grant 

closeout checklist and notify the grantee via the “Notification of Closeout 

Letter” after the following criteria have been met:

a. The final performance report has been received, reviewed, and accepted;

b. All other terms of the grant were met; and

c. A review of the financial status in the grants management system

indicates that no funds remain in the grant account.

1) The “Notification of Closeout Letter” informs the grantee of the status 

of their award and reminds them of the record retention requirements 

in 2 C.F.R. §§ 200.334 - 200.338

4. Closing a grant with fund balances. If the final performance report was 

received, reviewed, and accepted, and all other terms of the grant were met, 

but the grants management system indicates that funds remain on the grant, 
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program offices respond in either of the following ways before closing the 

grant:

a. If 10 percent or more of the Federal funds made available to the grantee in 

the final budget period (or the project period, for grants with only one 

budget period) remain in the grant account, program offices contact the 

grantee before de-obligating the funds and ask for a letter or email 

verifying that the funds are not needed, and that all of the financial 

obligations of the grant were met. The grantee’s certifying official should 

send the email or sign the letter. Upon receiving this information, the 

program offices close out the grant. If the grantee previously submitted a 

final FFR report, if applicable, or final performance report that has an 

explanation of the balance of funds, program offices may determine that it 

is not necessary to contact the grantee. An authorized license holder then 

de-obligates the funds and approves the closeout. 

b. If the grantee wants to draw down any of the remaining funds, program 

offices require the grantee to provide a written request and justification for 

using the funds, and an FFR. The request and the FFR are signed by the 

certifying official, or the individual authorized to record and report the 

grant’s finances (expenditures and obligations), or the individual delegated 

the authority to respond on behalf of the certifying official. If program 

offices approve the request, a license holder modifies the liquidation dates 

in the grants management system to allow the grantee to draw down the 

agreed amount of funds. The drawdown period should not exceed 30 

calendar days. If the request is not approved, program offices ask an 

authorized license holder to de-obligate the remaining funds and approve 

the closeout. The program official signs and sends to the grantee a letter 

informing the grantee of the disapproval.

c. When the funds remaining on the grant represent less than 10 percent of 

the funds available in the final budget period (or the project period, for 

grants with only one budget period), the program staff determines, based 

on their knowledge of the project, if any follow-up with the grantee is 

necessary.

d. If program staff determines that follow-up with the grantee is unnecessary, 

program staff asks an authorized license holder to de-obligate the 

remaining funds and approve the closeout. 

5. Closing a grant in noncompliance. A grant closed out in noncompliance 

may seriously affect a grantee’s ability to receive awards under future grant 

competitions with ED (see EDGAR § 75.217). Therefore, it is critical that 

program offices ensure that this happens rarely and only in appropriate 

circumstances. If the grantee has failed to comply with a material requirement 

under the grant, program offices close the grant in noncompliance.
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a. However, if a missing final performance report is the reason for 

noncompliance, program offices contact grantees to obtain the report. 

Program offices make documented good faith efforts by contacting the 

grantee in writing to request submission of the final report. Program offices 

apply the following steps when contacting a grantee for a missing final 

performance report:

b. Provide official notification to the grantee either by letter, or email, with a 

reasonable deadline to submit the missing final performance report.

c. If the grantee fails to meet the deadline identified in the first notification, 

provide a follow-up notification (e.g., an email with return receipt or 

certified letter with return receipt) with reference to the initial notification. 

The follow-up notification should provide an additional five business day 

deadline and include language indicating that failure on the grantee’s part 

to respond with the missing final performance report will result in the grant 

being closed in noncompliance.

d. If the program office’s efforts to get the missing report are unsuccessful or 

the grantee has failed to comply with a material requirement of the grant, 

program offices close the grant in noncompliance using the following 

steps:

1) Issue a Noncompliance Letter signed by the program official explaining 

the basis for the noncompliance and whether the grantee materially 

failed to meet the requirements of the grant;

2) Place a copy of the letter in the official grant file along with the 

documentation of the program’s efforts to resolve any noncompliance 

issues, and the documentation of the consultation between the 

program and the program official concerning the close out of the grant 

in noncompliance; and

3) In the grants management system, the noncompliance indicator in the 

award history screen is checked and the reason that the grant was 

closed out in noncompliance is recorded.

4) Report the grantee’s material failure to comply with the terms and 

conditions of the award to FAPIIS, and may pursue other enforcement 

actions in accordance with 2 C.F.R. § 200.339

6. Changing the closeout status of an award in the grants management 

system. A grantee may need to contact the program office to adjust their 

grant’s financial data and request authorization to draw down funds for 

obligations incurred during the performance period. This usually occurs after 

the grant’s liquidation period has ended and the grant is in the suspension or 

manual closeout status in the system. Program offices review the request and 
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contacts the grantee, if necessary, to confirm the need and amount of the 

draw down and the time needed to complete the transaction.

7. After careful review of the request, the program may authorize the draw 

down:

a. If the grant is in the suspension status, by changing the grants closeout 

status in the grants management system from suspension back to 

liquidation and extending the liquidation period for a period not to exceed 

30 calendar days on any single request and 60 calendar days 

cumulatively for all requests; or

b. If the grant is in the manual closeout status, by requesting a license holder 

to review and approve the request, and move the grant from manual 

closeout status back to the liquidation status; or 

c. If the grant is in the closed status, by requesting a program official to 

reinstate the grant following the procedures described in the section 

Processing a Reinstatement. 

8. A system edit and corresponding flag prevents program staff from processing 

in the grants management system any single extension of the liquidation 

period that exceeds a 30 calendar-day time period. Further, a flag alerts the 

program that the grantee has already received cumulative extensions of 60 

calendar days or more and that only the license holder can approve and 

process any further extension of the liquidation period in the system. The 

license holder documents the official grant file stating the reasons for 

approving an extension of the liquidation period beyond a 60 calendar- day 

period.

C. Guidance – Reserved

D. Other Pertinent Information

1. Templates for each of the letters referenced in this section are in the grants 

management system award closeout module. They are also provided for 

reference purposes at the following link: Documents and Forms Referenced 

in the Handbook for the Discretionary Grant Process. 

2. Electronic files stored in the grants management system or other ED 

approved recordkeeping systems (NARA compliant) do not need to be sent to 

the FRC.

3. Grant Award Notification attachment 2 (Specific Grant Terms and Conditions 

for Financial and Performance Reports) addresses financial and performance 

reporting requirements. The official version of this attachment is stored in the

grants management system. 
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6.17 Processing a Reinstatement

A. Policy

1. A grant reinstatement reopens and restores Federal funds to a grant for which 

unused fund balances were de-obligated as part of the closeout process.

2. Reinstatements are only initiated in rare circumstances such as a grant 

prematurely closed, and funds de-obligated.

3. Program staff monitor grant activities and review grantee expenditure 

histories in the grants management system and provide TA to grantees 

throughout the project period to avoid reinstatements.

B. Procedures

1. Program staff coordinate the reinstatement with the program official and

receives an approval from the program official to submit the necessary 

paperwork to the Executive Office before the program staff may reinstate a 

grant.

2. Program staff implement the reinstatement process as follows:

a. Program offices first obtain from the grantee a written request to reinstate 

the grant, which include:

1) The PR/Award and UEI number and an FFR;

2) The total actual dollar amount of expenditures for which reinstatement 

is needed, not to exceed the grant award authorization for the project 

period; and

3) A written statement describing the allowable costs for which the funds 

will be used, why this use of funds should be allowed, and why the 

funds were not drawn during the performance or liquidation periods of 

the grant closeout process.

b. Upon receipt of the grantee’s written request, program offices conduct a 

review to:

1) Verify the grantee’s name, address, and UEI number in the grants

management system;

2) Verify the information provided on the FFR against the award history 

information in the system;
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3) Determine whether the costs were authorized under the grant, if an 

adjustment is needed, and whether the obligations underlying the 

expenditures occurred prior to the grant’s project period end date; and 

4) Ensure that the reinstatement amount does not exceed the amount 

authorized for the project period and that the appropriation is available 

for adjustments (31 U.S.C. § 1553).

c. The program official submits a “Use of Prior Year Funds Request” to the 

Executive Officer for review and verification. The Executive Officer, after 

review, submits the form to the Budget Execution and Administrative 

Analysis Division (BEAAD) for approval. BEAAD is required to review and 

approve the use of prior-year funds. BEAAD approval is needed to 

determine if enough funds exist in the program appropriation account to 

allow the grantee to make the needed adjustments. The Executive Officer 

provides the following information to BEAAD: 

1) The grantee’s written request for reinstatement of funds;

2) A copy of the original GAN and any amendments reflecting the 

grantee’s total award amount;

3) Documentation validating the prior year obligation, and the FFR

showing an available unobligated balance; and

4) A copy of any requests for written advice from the program attorney, if 

the obligation adjustment involves legal issues (such as written advice 

pertaining to the validity of the grantee’s request).

3. BEAAD reviews the request for the use of prior-year funds and other 

documents to either:

a. Approve the request, issue any allotment changes needed, and return the 

package to the Executive Office; or

b. Disapprove the request, return the package to the program official via the 

Executive Office, and suggest alternative methods of funding the 

reinstatement (such as use of current year funds). 

4. If BEAAD approves the request to use prior-year funds, the license holder 

reinstates the grant in the grants management system for a period not to 

exceed 30 days. The closeout function/reinstatement sub-function is used to 

reopen a closed discretionary award and reinstate funds to a grant.

5. If BEAAD determines that the appropriation is cancelled, or that prior year 

funds are not available for the reinstatement, the program official (with the 

approval of the Principal Officer) may use grant funds available for the 
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purposes of the program and from a current-year program appropriation to 

allow the grantee to make the needed adjustments. In accordance with 31 

U.S.C. § 1553, a principal office may only use up to one percent of a current 

appropriation for the program for reinstatements.

6. Program offices ensure that a copy of the grantee’s request, other supporting 

materials, and the signed Use of Prior Year Funds Request Form, from 

BEAAD, are placed in the grantee’s official file.

C. Guidance

1. The funds needed for a grant reinstatement are usually available from the 

appropriation account under which the original award was made.

2. Program office’s appropriation accounts are canceled five fiscal years after 

the last date that ED could obligate the funds; therefore, in some cases, it 

may be necessary to request funds from a current year appropriation account 

to restore funds to the grant. As a general matter, however, ED has no legal 

obligation to use current-year funds to help a grantee liquidate an old 

obligation.

D. Other Pertinent Information

1. Information about the “Use of Prior Year Funds Request” form can be found 

in ACSD-OFO-052, Upward Adjustments to Obligations in Expired 

Expenditure/Appropriation Accounts. 

6.18 Sharing Results

A. Policy

1. Program offices review products before they are disseminated to ensure the 

information ED shares is useful, accurate, reliable, unbiased, and secure, and 

consistent with the guidelines found in the: Information Quality Guidelines. 

B. Procedures

1. If a grantee produces materials that meets the standards below, program 

offices review the material to ensure that it meets the standards of the 

Guidelines.

2. Under the Guidelines, publications, audiovisual products, and websites 

produced by grantees and recipients of cooperative agreements are subject 

to the guidelines if ED:

a. Represents or uses the information as the official position of ED, or in 

support of the official position of ED;
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b. Has authority to review and approve the information before release; or

c. Directs that the information be disseminated.

C. Guidance

1. Program offices should identify successful projects within their grant

programs that contributed significantly to the goals of the program’s mission 

and have national significance and share this information with other grantees, 

potential grantees, and the public. Program offices may disseminate 

information:

a. Using the Education Resource Information Center (ERIC) clearinghouse 

and national centers.

b. With the educational community through its website, training, TA, and 

conferences.

2. Some of the material developed by grantees and recipients of cooperative 

agreements might be subject to ED’s Information Quality (IQ) Guidelines.

D. Other Pertinent Information

1. Questions about sharing information and materials on the web, or about ED’s 

Guidelines, should be referred to the Information Assurances staff in OCIO.

2. The Information Quality Guidelines are available at: Information Quality 

Guidelines. 

6.19 Freedom of Information Act (FOIA) Request

A. Policy

1. Program offices comply with the Freedom of Information Act (FOIA)(5 

U.S.C.§ 552). In general, all agency records are made available to the public 

except for those portions of records that fall under one of nine FOIA 

exemptions:

a. Exemption One, Information properly classified to prevent harm to national 

security; 

b. Exemption Two, Information related to internal personnel rules and 

practices; 

c. Exemption Three, Information specifically exempted from disclosure by 

another Federal statute;
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d. Exemption Four, Commercial information that is privileged or confidential;

e. Exemption Five, Interagency or intra-agency communications that would 

be unavailable to a party in litigation with the agency;

f. Exemption Six, Information that would, if released, constitute a clearly 

unwarranted invasion of personal privacy;

g. Exemption Seven, Information compiled for law enforcement purposes;

h. Exemption Eight, Information contained in records concerning financial 

institutions; and

i. Exemption Nine, Geological or geophysical-related documents.

B. Procedures

1. Program offices follow requirements in ACSD-OS-002 “Freedom of 

Information Act and Privacy Act Requests”, in response to all FOIA requests.

C. Guidance

1. The Freedom of Information Act (FOIA)(5 U.S.C. § 552) provides that any

person or organization (excluding Federal agencies) has the right to request 

access to Federal agency records or information.

2. Program offices are advised to contact ED’s FOIA office for assistance when 

handling complex information requests, requests requiring greater sensitivity, 

privacy issues, or other matters pertaining to FOIA.

3. The following list identifies some of the most requested discretionary grant 

items requested from ED under FOIA:

a. Funded or unfunded grant applications

b. Grant application reviewer information (comments, evaluations, reviewer 

lists)

c. Funding slates and rank order lists

d. Procedures for the Review of Applications (Application Technical Review 

Plan)

e. Project materials

f. Data in the grants management system

g. Program–specific reports
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h. Information regarding discretionary grants that have been closed out and 

sent to the Federal Records Center

D. Other Pertinent Information

1. For detailed information about what information may be released in response 

to a FOIA request for any of the above listed items, programs are directed to 

ACSD-OS-002 “Freedom of Information Act and Privacy Act Requests”. This 

FOIA directive provides in-depth discussion of the Act and ED procedures 

and guidelines for processing and responding to FOIA requests.

6.20 Internal Review of ED’s Discretionary Grant Processes

A. Policy

1. To ensure fairness, objectivity, and consistency across all of ED’s programs 

and to promote continuous improvement, GMPD works in partnership with 

each POC to identify strengths and weaknesses in ED’s discretionary grant 

processes. 

B. Procedures – Reserved

C. Guidance

1. In carrying out this responsibility GMPD may review:

a. Principal office discretionary grant award competition files;

b. Funded discretionary grant award files;

c. Application review procedures and processes;

d. Application technical reviewer comments and evaluations of the review 

process; 

e. Novice applicant and New Potential Grantees procedures;

f. Monitoring activities under selected programs;

g. Grant administration activities under selected programs;

h. Grant closeout processes under selected programs; and

i. Grants or grantees designated high risk.

2. After each review, GMPD will communicate with POCs to discuss the 

information learned, and the next steps, if any. The discussion will cover the 

strengths and weaknesses of the implementation of grants administration 
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policy administered by the various POCs and make recommendations for 

improvements, as needed. GMPD in collaboration with POCs, and other staff 

offices as necessary, establish a plan that consists of measurable steps to 

improve the process, including any necessary training. Additionally, GMPD

may issue final reports regarding ED’s discretionary grant processes for 

specific programs, offices or for ED.

D. Other Pertinent Information - Reserved
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GLOSSARY

Absolute Priorities. See Funding Priorities.

Agreement for Grant Application Reviewers Who Receive Compensation. A 

document signed by each reviewer receiving compensation. The document includes a 

conflict of interest certification and other statements about the duties and responsibilities 

of a reviewer.

Agreement for Grant Application Reviewers Who Serve Without Compensation. A 

document signed by each non-paid reviewer that waives any right to payment or 

compensation for services rendered. The document includes a conflict of interest 

certification and other statements about the duties and responsibilities of a reviewer. 

Travel or per diem costs provided by ED under the Federal Travel Regulations are not 

considered compensation for the purposes of this agreement.

Allocable Cost. Cost that can be traced to specific activities of a grant project.

Allowable Cost. A cost incurred by a grantee that is:

1. Necessary and reasonable for the performance of the award;

2. In conformance with any limitations or exclusions set forth in the Federal cost 

principles applicable to the organization incurring the cost or in the Grant 

Award Notice as to types or amount of cost items;

3. Consistent with the grantee’s policies and procedures that apply uniformly to 

both Federally financed and other activities of the grantee;

4. Determined in accordance with generally-accepted accounting principles; and

5. Not included as a cost in any other Federally financed grant (unless 

specifically authorized by statute).

Annual Performance Report. A report a grantee must submit to receive continued 

funding under a multi-year award. The report provides the most current performance 

and financial information about a discretionary grant or cooperative agreement (see 

EDGAR § 75.118). POCs are strongly encouraged to use the Grant Performance 

Report form (ED 524B) for their grantees to submit their grant performance and financial 

data to ED.

Application Notice. See Notice Inviting Applications.

Application package. A package that contains the application notice for one or more 

programs and all the information and forms needed to apply for a discretionary grant 

(see EDGAR § 75.125) under one of those programs.

Application reviewer. See Peer Reviewer.
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Application Technical Review Plan (ATRP). A plan that describes the competitive 

procedures used by a POC to conduct a new grant competition; this is an internal 

document.

Appropriations Statute. A statute passed by Congress to make funds available for the 

purposes specified in the statute (such as grant programs).

Approval (or Authorization). The documentation showing ED’s express written 

consent for a grantee to incur a specific cost or take an action if the cost or action 

requires prior approval.

Approved Budget. The budget submitted by the grantee and any revisions for which 

approval is necessary by the POC and which have been approved. The approved 

budget includes cost items for Federal funds and may include cost items for nonFederal funds, if cost sharing or matching is required or volunteered (see EDGAR § 

75.232).

Assistance Listings (AL). Refers to the publicly available listing of Federal assistance 

programs managed and administered by the General Services Administration, formerly 

known as the Catalog of Federal Domestic Assistance (CFDA). 

Assistance Listing Number (ALN). Refers to a unique number assigned to identify a 

Federal Assistance Listings. It is composed of a unique two-digit prefix to identify the 

Federal agency that makes the funds available (ED’s prefix is 84). A period and a 

unique three-digit code for each authorized program follow the prefix. It is formerly 

known as the CFDA Number. 

Assistance Listing Program Title. Refers to the title that corresponds to the Federal 

Assistance Listings Number, formerly known as the CFDA program title. 

Assurances. A listing of requirements found in different Federal laws, regulations, and 

executive orders that apply to grants, and to which applicants must agree in writing to 

observe as a condition of receiving Federal assistance (see 2 C.F.R. § 200.209).

Audit Finding. A conclusion about a monetary or non-monetary matter related to an 

auditor’s examination of an organization, program, activity, or function, which frequently 

identifies problems and provides recommendations for corrective action to prevent their 

future recurrence.

Audit Resolution. The process used to resolve audit findings and recommendations, 

including management and systems deficiencies and monetary findings (e.g., 

questioned costs (2 C.F.R. part 200 Subpart F).

Authorizing Statute. A statute passed by Congress that establishes or continues a 

grant program either indefinitely or for a specified period. An authorizing statute is 

generally a prerequisite for appropriations.

Authorized Representative. The individual entrusted by the applicant/grantee 

organization to sign the application and the applicable assurances and certifications on 
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behalf of the organization. The governing body’s authorization for this entrusted 

individual to sign an application as official representative must be on file in the 

applicant’s office.

Award. See Grant.

Budget Period. An interval of time into which a project period is divided for budgetary 

purposes, usually twelve months (see EDGAR § 77.1).

Carryover Balance. Unexpended funds of the grantee from a previous budget period 

under a grant that are authorized for use to cover allowable costs in a current budget 

period (see EDGAR § 75.253).

Catalog of Federal Domestic Assistance (CFDA). See Assistance Listings 

CFDA Number. See Assistance Listing Number 

Code of Federal Regulations (C.F.R.). Compilation of all final regulations issued by 

Federal agencies and published annually by the National Archives and Records 

Administration (NARA), divided into numbered “titles.” Title 2 contains the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements and Title 34 

contains the applicable regulations of ED.

Cognizant Agency for Indirect Costs. The Federal agency responsible for reviewing, 

negotiating, and approving cost allocation plans or indirect cost proposals developed on 

behalf of all Federal agencies. 

Common Instructions. A set of centralized instructions for applicants applying to ED’s 

discretionary grant programs. All program NIAs reference this document in lieu of 

providing this series of instructions within each NIA.

Competition File. See Grant Program Competition File.

Competition Manager. The program official or ED staff person given the overall 

responsibility to ensure the fair treatment of all applications in a competition. This 

individual oversees the entire competition and provides the direction and guidance for 

all the panels conducted under the competition.

Competitive Preference Priorities. See Funding Priorities.

Competitive Review Process. The process used by ED to select discretionary grant 

applications for funding, in which applications are scored by Peer Reviewers and ED 

funds the highest qualified applications (see EDGAR § 75.217). 

Cooperative Agreement. A type of Federal assistance; essentially, a variation of a 

grant (see Grant), awarded by ED if it anticipates having substantial involvement with 

the grantee during the performance of a funded project, and which includes conditions 

regarding the character and extent of the collaboration (see Federal Grant and 

Cooperative Agreement Act of 1977; see also 34 C.F.R. § 75.234(b)).
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Cost Analysis. An examination and verification of cost data in the detailed budget 

submitted by applicants to determine if they are necessary, reasonable, and allowable 

under applicable statutes, regulations, and Federal cost principles to determine the 

amount of the grant to the applicant (see EDGAR § 75.232).

Cost Principles (Federal Cost Principles). The principles as set out by the Office of 

Management and Budget (OMB) for generally accepted accounting rules used to 

determine whether costs applicable to grants, contracts and other agreements are 

allowable, reasonable, and allocable. The Federal cost principles are found in 2 C.F.R. 

part 200 subpart E. 

Cost Sharing or Matching. The value of allowable third-party in-kind contributions and 

the allowable costs of a Federally assisted project or program not borne by the Federal 

government (see 2 C.F.R. § 200.306).

Deadline Date. The date and time by which an applicant must submit an application to 

ED for a grant or cooperative agreement (see EDGAR § 75.102).

Directed Grant (also known as an Earmark). A grant that ED is directed by Congress 

through statute to award to a specific entity. These grants are subject to all the rules in 2 

C.F.R. parts 200, 3474, 3485, and EDGAR except those regarding competition and to 

the respective requirements in this Handbook.

e-Administration. ED’s electronic system that makes it possible for grantees to submit 

requests for administrative changes to their active grants directly to program staff via 

the Internet.

Earmark. See Directed Grant.

EDGAR (Education Department General Administrative Regulations). 

Administrative regulations governing ED’s grant programs found in parts 75, 76, 77, 79, 

81, 82, 84, 86, 97, 98 and 99 of Title 34 of the Code of Federal Regulations (C.F.R.) 

(defined above); a document issued by ED that contains a reprint of these regulations.

ED PUBS. The main distributor of hard-copy grant applications and other ED literature.

ED Staff Offices. Principal Offices of ED other than program offices that are involved in 

the planning, review, and award of discretionary grants. This includes the Office of 

Finance and Operations; the Office of Planning, Evaluation, and Policy Development; 

the Office of the General Counsel; the Office of the Chief Information Officer; and the 

Office of Legislation and Congressional Affairs.

Eligibility. Eligibility to apply for a grant under a program of ED is governed by the 

authorizing statute and implementing regulations for that program (see EDGAR § 

75.50).

Entity Risk Review (ERR). The ERR assists program offices in identifying and 

mitigating potential risks by reviewing grantee attributes drawn from the grants 

management system, Federal Audit Clearinghouse (FAC) and Dunn and Bradstreet 

data sources. Forty-one specific attributes are grouped into Administrative, Financial, 

and Internal Controls risk categories.
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e-Reader. ED’s electronic review system that supports the program office’s peer review 

process. 

e-Reports. ED’s electronic reporting system which makes it possible for grantees to 

submit their annual grant performance reports (ED 524B) to ED via the Internet.

Federal Award Identifier Number (FAIN). This is the award number, or other 

identifying number, assigned by the Federal awarding agency. The FAIN is a Federalwide term that is synonymous with ED’s PR/Award Number, and is a term used in 

FFATA reporting in the FFATA Subaward Reporting System (FSRS) and other reporting 

data systems.

Federal Financial Report (FFR). A standard form used to obtain financial information 

from grantees. ED grantees are required to submit this form if reporting program 

income, cost sharing or matching, or when required by program statute or regulation or 

a specific condition of their grant.

Federal Funding Accountability and Transparency Act (FFATA). This statute and its 

subsequent 2008 amendments seek to increase transparency and improve access to 

Federal Government information by:

1. Requiring information disclosure of entities receiving Federal funding through 

Federal awards such as Federal contracts and their sub-contracts, and 

Federal grants and their subawards; and

2. Requiring disclosure of executive compensation for certain entities.

Federal Grant and Cooperative Agreement Act. The Act which establishes standards 

Federal agencies must apply to determine whether a particular activity or agreement 

should be funded as a grant, cooperative agreement, or contract. Under the Act, an 

agency must use the correct instrument to fund a particular agreement even if Congress 

specified a different instrument in the authorizing statute (see Federal Grant and 

Cooperative Agreement).

Federal Program (Grant Program). Consists of Federal awards which are assigned a 

single number in the AL, or when no ALN is assigned, all Federal awards to nonFederal entities from the same agency made for the same purpose are combined and 

considered one program (see 2 C.F.R. § 200.1). Federal programs are authorized under 

statute or regulations to provide assistance on a particular matter of congressional 

concern.

Federal Register. A daily compilation of proposed and final Federal regulations, legal 

notices, presidential proclamations and executive orders, Federal agency documents 

having general applicability and legal effect, documents required to be published by act 

of Congress, and other Federal agency documents of public interest. The Federal 

Register is prepared by the National Archives and Records Administration (NARA) for 

public distribution by the Government Printing Office (GPO); it is the publication of 

record for the Federal government.
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Federal Service Desk (FSD; www.FSD.gov). Assists visitors with obtaining the 

information and assistance they need for the systems (i.e., Web sites) that the FSD 

supports, including SAM and Federal Subaward Reporting System (FSRS) among 

others.

Federal Share. Means the portion of the total project costs that are paid by Federal 

funds (see 2 C.F.R. § 200.1).

Federal Subaward Reporting System (FSRS; www.FSRS.gov). The Web site prime

awardees (i.e., ED’s grantees) use to capture and report subaward and executive 

compensation data for their first-tier subawards in accordance with FFATA reporting 

requirements.

Financial Reporting. Interim and final financial data provided by grantees as they 

make payment requests through ED’s grants management system. Grantees also 

provide financial data with their submissions of annual and final performance reports.

First-tier Subaward. For the purposes of FFATA reporting requirements, this is the 

subgrant made by the ED grantee to its subrecipient, and generally does not include 

any type of subgrants awarded by the subrecipient to any other entity.

For-profit. A for-profit organization (also called “commercial organization”) is an entity 

which is established with the intention or purpose of making a profit.

Frontloaded Grant. An informal term that commonly describes the use of appropriated 

funds available for obligation in a particular fiscal year to “pre-pay” grant costs in future 

years. 

Funding Priorities. A means of focusing a competition on the areas in which the 

Secretary is particularly interested in receiving applications. Generally, priorities take the 

form of specific kinds of activities that applicants are asked to include in an application. 

There are absolute priorities, which the applicant must address in order to be 

considered for funding; competitive preference priorities, which the applicant has the 

option of choosing whether or not to address and for which they may receive additional 

points; and, invitational priorities, which the applicant is encouraged but not required to 

address. Applications addressing invitational priorities receive no preference over 

applications that do not meet the priority (see EDGAR § 75.105).

Grant. EDGAR § 77.1(b) states (The terms “award,” “grant,” and “subgrant”, as defined 

in paragraph (c) of this section, have the same meaning, depending on the context, as 

“Federal award” in 2 C.F.R. 200.1). It means financial assistance, including cooperative 

agreements, that provides support or stimulation to accomplish a public purpose. 2 

C.F.R. Part 200, as adopted in 2 C.F.R. part 3474, uses the broader, undefined term 

“Award” to cover grants, subgrants, and other agreements in the form of money or 

property, in lieu of money, by the Federal Government to an eligible recipient. The term 

does not include: technical assistance, which provides services instead of money; other 

assistance in the form of loans, loan guarantees, interest subsidies or insurance; direct 

payments of any kind to individuals; and contracts which are required to be entered into 

and administered under procurement laws and regulations (see 2 C.F.R. part 3474 and 

2 C.F.R. § 200.1).
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Grant Award Notification (GAN). The official document signed by a license holder 

stating the amount and conditions of an award for a discretionary grant or cooperative 

agreement (see EDGAR § 75.235).

Grant Bulletins. GBs are the mechanism authorized for use by GMPD to update 

content in this Handbook in between the times the Handbook is updated and officially 

cleared by ED.

Grant Closeout. The process by which ED determines that all applicable administrative 

actions and all required work of a grant have been completed. ED also reconciles 

and/or makes any final fiscal adjustments to a grantee’s account in the grants 

management system. (see 2 C.F.R. § 200.344).

Grant Conditions. Requirements imposed by statute, regulation, absolute priority, or in 

the grant award document itself. The terms of a GAN may include both standard and 

specific conditions that are considered necessary to attain the objectives of the grant, 

facilitate post- award administration of the grant, conserve grant funds, or otherwise 

protect the Federal government’s interests.

Grantee. The legal entity to which a grant is awarded and that is accountable to the 

Federal government for the use of the funds provided. The grantee is the entire legal 

entity even if only a particular component of the entity is designated in the Grant Award 

Notification (GAN). See EDGAR § 77.1©. 

Grant File. The official grant file contains documents and correspondence applicable to 

the grant award for which the file is created.

Grant Funding Slate. An internal document required of POCs by ED to recommend 

funding for new grants, as well as other funding options. The Grant Funding Slate 

provides specific guidance regarding the information necessary for each funding option. 

The slate, which identifies the grant applications that are approved for funding, as well 

as the order in which they will be funded, is prepared by the program official and 

approved by the Principal Officer then submitted to the Office of Planning, Evaluation 

and Policy Development, Grants Policy Office (OPEPD/GPO) for internal clearance 

before routed through the Executive Secretariat to the Secretary for approval. 

Grants Management System. A financial subsystem that is part of the Education 

Department Central Automated Processing System (EDCAPS). ED’s grants 

management system provides online capabilities for grantees to request payments, 

obtain their most current payment information, access their GAN documents, request 

administrative changes to their grants, and file electronic reports. It is also the system 

through which ED staff manage aspects of the pre-award, award, post-award, closeout, 

and payments stages of the grants process.

Grant Performance Report. See Annual Performance Report.

Grant Period. See Project Period. Grant Program. See Federal Program.

Grant Program Competition File. A file that contains a collection of information, 

decisions or documentation related to a specific grant program competition or a group of 

related competitions.
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Grant Scheduling Representative. The person designated in each program office who 

is responsible for entering yearly milestones that establish grant schedules for new and 

continuation awards, and ensure schedules are kept current in the grants management 

system. 

Grant Transfer. A process whereby the legal and administrative responsibility for a 

grant- supported project or activity is transferred from one legal entity to another if 

certain limited conditions are met.

Guidance. Information that provides some general direction usually in the form of 

guides, templates, instructions, best practices, and applicable examples for 

consideration to assist POCs’ compliance with Federal statutes and regulations, 

executive orders, OMB circulars, and internal ED policies.

High Risk. A term used to describe the act of imposing specific high-risk conditions on 

a grant or grantee whose risk of failure is determined to be high, based on a history of 

poor performance or poor business practices, financial instability, or lack of a 

management system meeting the required financial management standards (for specific 

conditions see 2 C.F.R. § 200.208; for ED’s authority to designate a grantee as high 

risk, see 2 C.F.R. § 3474.10).

Human Subjects. Under Federal regulations, human subjects are defined as living 

individuals about whom an investigator conducting research obtains data through 

intervention or interaction with the individuals, or by collecting identifiable private 

information about the individuals (see EDGAR Part 97).

Improper Payment. A payment by a grantee that should not have been made. (see 2 

C.F.R. § 200.53).

Indirect Costs. Costs an organization incurs for common or joint objectives, which 

cannot be readily and specifically identified with a particular grant project or other 

institutional activity without effort in excess of the results achieved. 

Indirect Cost Agreement. Is a document that formalizes the indirect cost rate 

negotiation process between a grantee and the Federal Government. This document 

typically contains:

1. The type of rate(s) negotiated;

2. The effective period(s) of the rate(s);

3. The indirect cost rate(s);

4. The distribution base;

5. The location(s) to which the rate(s) is/are applicable;

6. The program(s) to which the rate(s) is/are applicable;

7. It also provides information on the base(s) used to distribute indirect costs, 

and the treatment of fringe benefits and paid absences; and
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8. Particulars indirect cost rate limitations, accounting changes, 

provisional/final/predetermines, fixed rate, notification to other Federal 

agencies, Audit, reimbursement ceilings/limits on rates, alternative 

reimbursement methods, and submission of proposals.

9. The indirect cost negotiation agreement must be signed by both the grantee‘s 

authorized representative and the grantee’s cognizant agency’s indirect cost 

coordinator or authorized representative.

Indirect Cost Rate Proposal. The documentation prepared by a non-Federal entity to 

substantiate its request for the establishment of an indirect cost rate (see 2 C.F.R. § 

200.57).

Indirect Cost Rate. A percentage established by a Federal department or agency for a 

grantee organization or sub-organization, which the grantee uses in computing the 

dollar amounts it charges to the grant to reimburse itself for indirect costs incurred 

during the grant project (see EDGAR §§ 75.560 and 76.560).

In-Kind Contribution. A contribution directly benefiting a grant-supported project that is 

provided by or to the grantee by non-Federal third parties. In-kind contributions may be 

in the form of real property, equipment, supplies and other expendable property, and 

goods and services directly benefiting and specifically identifiable to the project or 

program (see 2 C.F.R. § 200.96). In-kind contributions are generally used by grantees 

to meet cost sharing or matching requirements.

Institutional Review Board (IRB). An administrative body established by a recipient to 

protect the rights and welfare of human research subjects recruited to participate in 

research activities conducted under the auspices of the institution with which it is 

affiliated. The IRB has the authority to approve, require modifications in, or disapprove 

research activities that fall within its jurisdiction. See EDGAR Part 97. 

Internal Controls. A process, implemented by a grantee, designed to provide 

reasonable assurance regarding the achievement of objectives in the following 

categories:

1. Effectiveness and efficiency of operations;

2. Reliability of reporting for internal and external use; and

3. Compliance with applicable laws and regulations.

See 2 C.F.R. § 200.612. 

Invitational Priorities. See Funding Priorities.

License. An authorization provided by GMPD to an individual ED employee that allows 

that person to record obligations and sign and issue new, NCC or revised grant awards 

for specific AL, and make obligations up to certain amounts for discretionary grants and 

cooperative agreements.
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License Holder. An individual who has met the qualifications to receive and has 

received a license in order to record and make obligations.

No-Cost Extension. An extension of time to the last or only budget period of a project 

to complete the work of the grant during that period, without the obligation of additional 

funds by the Federal government (see 2 C.F.R. § 200.308 and EDGAR § 75.261).

Non-competing Continuation (NCC). A grant for a budget period subsequent to the 

first budget period. A grantee does not have to compete with other applicants to receive 

this award (see EDGAR § 75.251).

Non-Federal Share. The portion of allowable project costs not borne by the Federal 

government (see 2 C.F.R. § 200.306).

Non-profit. Non-profit as applied to an agency, organization, or institution, means that it 

is owned and operated by one or more corporations or associations whose net earnings 

do not benefit, and cannot lawfully benefit, any private shareholder or entity (see 

EDGAR Part 77).

Notable Results. An outcome or accomplishment that is worthy of attention, notice, or 

replication.

Notice Inviting Applications (NIA or Notice). A notice published in the Federal 

Register (see Federal Register) that invites applications for one or more discretionary 

grant or cooperative agreement competitions. The notice gives basic program and fiscal 

information on each competition, informs potential applicants when and where they can 

obtain applications, and cites the deadline date (see Deadline Date), for a competition 

(see EDGAR § 75.100).

Notice of Funding Opportunity (NOFO). See Notice Inviting Applications.

Notice of Proposed Rulemaking (NPRM). An announcement published in the Federal 

Register of proposed new regulations or modifications to existing regulations; the first 

formal stage in the process of creating or modifying regulations for most programs.

Novice Applicant. Any applicant for a discretionary grant from ED that meets the 

standards in EDGAR § 75.225. Generally, a novice applicant for a grant is an entity that:

1. Never received a grant before from the program to which they are applying;

2. Never been a member of a group application that received a grant from the 

program to which they are applying; and

3. Not had an active grant from the Federal Government in the five years before 

the deadline date for applications under the ED discretionary grant programs 

to which they are applying.

Objective. The goals and strategic purpose of a grant as described in the application 

and determined in the context of the grant program funding the award.
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Obligation. At the Federal level, the legal act of signing the GAN and sending it to the 

grantee. The obligation date may be referred to as the Federal award date (see 2 

C.F.R. § 200.39). At the grant level, one of the legal acts specified in EDGAR § 75.707. 

Office of Management and Budget (OMB). An agency within the Executive Office of 

the President that helps the President formulate spending plans; prepare the budget for 

submittal to Congress; evaluate the effectiveness of agency programs, policies, and 

procedures; assess competing funding demands among agencies; set government-wide 

funding priorities; manage Federal information collection; and manage the Federal 

government’s regulatory procedures.

Oracle Financial. The system software ED uses to support its financial management 

and business processes.

Pass-through Entity/Grantee. A non-Federal entity that provides a subaward to a 

subrecipient to carry out part of a Federal program (see 2 C.F.R. § 200.74).

Peer Reviewer – (Application Reviewer or Reviewer). An individual who serves ED 

by reviewing new discretionary grant and cooperative agreement applications.

Performance Measure. Any quantitative indicator, statistic, or metric used to gauge 

program or project performance (see EDGAR § 77.1©).

Performance Period. See Project Period.

Post-Award Performance Conference. A conference between ED and grantees after 

a new award has been made; may be telephonic, in-person, or otherwise.

PR/Award Number. The identifying number for an application and discretionary grant 

or cooperative agreement, composed of seven parts

Example – H029A951234-95C – 

1. POC designator (H)

2. AL numeric suffix of the program (029)

3. Alphabetic sub-program identifier (A)

4. Last two digits of the fiscal year of the competition (95)

5. Unique application identifier (1234)

6. Last two digits of the fiscal year of the funding (95)

7. Sequential order of the most recent funding action in a fiscal year, expressed 

alphabetically © 

The first five parts remain the same throughout the life of the project period while the 

last two parts change by budget period.

Pre-Application. A summary statement a POC requests or requires from potential 

applicants to determine: 1) the applicant’s intent to request Federal funds under a 
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program; 2) the applicant’s eligibility; 3) the quality of the proposed project compared to 

similar applications; and 4) which applications have little or no chance for Federal 

funding so ED can inform the applicant before it incurs significant expenditures to 

prepare an application. The pre-application process is in addition to the application 

process. 

Pre-Award Cost. The cost incurred prior to the effective date of the award and in 

anticipation of the award (see 2 C.F.R. § 200.308 and EDGAR § 75.263).

Prime Awardee. Is a Federal agency’s direct grant recipient.

Principle Office Component (POC). One of six principal offices of ED responsible for 

administering programs that award discretionary grants and cooperative agreements: 

Institute of Education Sciences (IES); Office of English Language Acquisition (OELA); 

Office of Elementary and Secondary Education (OESE); Office of Postsecondary 

Education (OPE); Office of Special Education and Rehabilitative Services (OSERS); 

and Office of Career Technical and Adult Education (OCTAE).

Principal Officer. The ED official who is head of one of the six POCs (listed above) and 

who holds the rank of Assistant Secretary or its equivalent.

Prior Approval. The written permission provided by the authorized program staff 

member from the ED awarding office before the grantee may undertake certain 

activities (such as performance or modification of an activity), expend funds or exceed a 

certain dollar level. 

Program Income. The gross income received by the grantee or cooperative agreement 

recipient that is directly generated by the supported activity or earned as a result of the 

award (see 2 C.F.R. §200.80).

Program Office. A sub-unit of a POC that conducts the daily work of administering ED 

discretionary grant or cooperative agreement programs, including the responsibility for 

the review and ranking of applications.

Program Office Scheduling Representative (PO Scheduler). Program office staff 

with access to planning and scheduling activities of the grant setup functionality in the

grants management system.

Program Official. A program manager having various oversight responsibility for the 

planning, review, pre-award/award, and post-award activities in the discretionary 

process. This person frequently acts as a level of review and approval for various 

procedures described throughout the Handbook.

Program Regulations. Regulations that implement statutes passed by Congress to 

authorize a specific grant program; they may include applicant and participant eligibility 

criteria, nature of activities funded, allowability of certain costs, selection criteria under 

which applications will be selected for funding, and other information relevant to the 

program.

Program Staff. Individuals who handle the day-to-day program office responsibilities as 

assigned by the program official.
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Project Cost. The total allowable costs incurred under a Federal award and all required 

cost sharing or matching and voluntary committed cost sharing or matching, including 

third-party contributions (see 2 C.F.R. § 200.83). 

Project Director. An individual designated by the grantee to direct the project or 

program being supported by a grant. The project director is responsible and 

accountable to officials of the grantee organization for the successful outcome of the 

project, program or activity.

Project Period (Performance Period). The period established in the award document 

during which Federal sponsorship begins and ends (see EDGAR § 77.1© and “Period of 

Performance” 2 C.F.R. § 200.77).

Project Scope. The nature and extent of the work to be performed under a grant as 

described in the application.

Reasonable Cost. A cost is reasonable if, in its nature or amount, it does not exceed 

that which would be incurred by a prudent person under the circumstances prevailing at 

the time the decision was made to incur the cost. 

Recipient. See Grantee.

Record of Obligation. An entry made by a license holder in ED’s automated 

accounting system that authorizes the payment of Federal grant funds to a grantee. A 

record of obligation does not obligate funds to a grantee. See Obligation, which defines 

the legal act of signing and sending a GAN.

Reviewer Database. A list of qualified Federal and non-Federal individuals from which 

ED selects reviewers of applications for new grants. Each POC may maintain its own 

register, but they are encouraged to use the grants management system’s centralized 

database.

Reviewer Roster. A list of individuals approved by the Principal Officer to review 

applications for new grants in a specific competition or competition cycle.

Risk. A measure of the potential inability to achieve overall program objectives within 

defined requirements related to cost, schedule, legislative authority, and grant 

management practice.

Risk Evaluation. An analysis and summary of risks associated with a potential grant 

award. The purpose of the risk evaluation is to analyze the possible effect of risks on 

grant implementation, the significance of that effect, the likelihood that it will occur or 

recur, estimate its likely occurrence or recurrence, and serves as the basis for 

determining how the risks should be managed.

Risk Identification. The identification of external risk factors, such as those that arise 

from interactions between an applicant or a grantee and other entities, and internal risk 

factors including those that are entity-wide and those that are grant project specific. Risk 

identification may occur during day-to-day oversight, official grant monitoring, or while 

conducting risk evaluations before obligating new, continuation, and supplement 

awards.
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Risk Information Sharing. Sharing, within program offices and across all ED offices, 

risk- related data, mitigation actions and strategies, and grants administration 

improvements.

Risk Mitigation. Identifying and implementing activities and/or strategies to mitigate or 

manage risks associated with an applicant or grantee.

Statute. As it relates to discretionary and formula grants, a statute is a law passed by 

Congress that establishes and authorizes a discretionary or formula grant program.

Stewardship. The management of assistance programs exercised by Federal officials. 

Program staff oversee the process of reviewing and awarding grants and participate in 

the oversight of awarded grants to ensure that funding is properly used, that all 

applicable laws and regulations are followed, and that the objectives of the authorizing 

statute are furthered.

Subaward. An award provided by a pass-through entity to a subrecipient for the 

subrecipient to carry out part of a Federal award received by the pass-through entity. It 

does not include payments to a contractor or payments to an individual that is a 

beneficiary of a Federal program. A subaward may be provided through any form or 

legal agreement, including an agreement that the pass-through entity considers a 

contract. 

Subgrant. An award of financial assistance in the form of money, or property in lieu of 

money, made under a grant by a grantee to an eligible subgrantee. The term includes 

financial assistance when provided by contractual or any other form of legal agreement, 

but does not include procurement purchases, nor does it include any form of assistance 

that is excluded from the definition of “grant or award” (see EDGAR § 77.1©). Also, the 

term “subgrant” has the same meaning as “subaward” in 2 C.F.R. § 200.1. 

Subgrantee. The government or other legal entity to which a subgrant is awarded and 

that is accountable to the grantee for the use of the funds provided (see EDGAR § 

77.1©).

Subprogram. A unique component of a program awarded under the umbrella of an 

existing AL program. (For example, the GEAR UP program, AL No. 84.334, has two 

subprograms: 84.334A – GEAR UP Partnership and 84.334S – GEAR UP State 

Programs.)

Subprogram Titles. The program name that identifies the subprogram.

Substantial Progress. A level of achievement that a grantee must make towards 

meetings its project goals, objectives and performance measures, if applicable in its 

project during a budget period, so the grantee can receive a continuation award (see 

EDGAR § 75.253).

Subrecipient. An entity, usually but not limited to non-Federal entities, that receives a 

subaward from a pass-through entity to carry out part of a Federal award; but does not 

include an individual that is a beneficiary of such award. A subrecipient may also be a 

recipient of other Federal awards directly from a Federal awarding agency. 

Supplemental Award. Additional Federal funds obligated to an existing grant.
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Supplies. All tangible personal property other than defined as Equipment.

Suspension Status. One of the phases in the close-out process.

System for Award Management (SAM). A system that combines a number of Federal 

systems, including the Central Contractor Registry (CCR) and EPLS, into one system 

for the purpose of streamlining and integrating processes, and eliminating data 

redundancies.

Termination. The permanent cancellation of a grantee’s authority to obligate all or part 

of the funds that have been awarded to it. It also means the grantee’s voluntary 

relinquishment of that authority. Termination is distinct from ED’s refusal to provide 

additional funds through a continuation award (denial of refunding/withholding of 

support). See Remedies for Noncompliance beginning at 2 C.F.R § 200.339. 

Tax Identification Number (TIN). The Federal Tax Identification Number is the unique 

nine- digit number used by the Internal Revenue Service (IRS) in the administration of 

tax laws. It is issued either by the Social Security Administration (SSA) or by the IRS. A 

Social Security number (SSN) is issued by the SSA whereas all other TINs are issued 

by the IRS.

The following are all considered TINs according to the IRS (see Tax Payer Identification 

Numbers).

1. Social Security Number “SSN” 

2. Employer Identification Number “EIN” 

3. Individual Taxpayer Identification Number “ITIN” 

4. Taxpayer Identification Number for Pending U.S. Adoptions “ATIN” 

5. Preparer Taxpayer Identification Number “PTIN” 

Unique Entity Identifier (UEI). A number used to identify a specific commercial, 

nonprofit, or Government entity. The Unique Entity Identifier (UEI) is used within 

SAM.gov as a primary key to uniquely identify an entity or part of an entity.

1. Unique Entity - An entity or part of an entity whose identifying information 

does not match that of any other entity doing business with the Federal 

government.

2. Entity - Organizations or individuals applying for financial assistance, contract 

awards, loans, grants or who need to register to do business with the Federal 

government, including but not limited to sole proprietors, corporations, 

partnerships, governments agencies, non-profits, etc.

Unsolicited Application. An application submitted to ED in writing and solely on the 

applicant’s own initiative, without prior formal or informal solicitation by any Federal 
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government official. The application’s content may or may not fall within the scope of 

activities that can be supported under a grant program funded by ED and must be 

analyzed under EDGAR § 75.222 to determine whether it may be funded.

USASpending.gov. The searchable Web site (USASpending.gov), accessible to the 

public at no cost, which includes for each Federal award: 1) the name of the entity 

receiving the award; 2) the amount of the award and executive compensation data; 3) 

information on the award including transaction type, funding agency, etc.; 4) the location 

of the entity receiving the award; 5) the unique FAIN of the entity receiving the award; 

and 6) first-tier subaward data (including subaward amounts and executive 

compensation data), which is provided by FSRS. 
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ACRONYMS and ABBREVIATIONS APPEARING in this 

HANDBOOK

A

AARTS Audit Accountability and Results Tracking System 

ACC Application Control Center

ACS Administrative Communication System

APR Annual Performance Report

ARD Audit Resolution Division

ATIN Taxpayer Identification Number for Pending U.S. Adoptions 

ATRP Application Technical Review Plan

B

BEAAD Budget Execution and Administrative Analysis Division 

Budget Service Office of Budget Service

BPCD Budget Policy and Coordination Division

BSSD Business Systems Support Division

C

CAM Contracts and Acquisitions Management

CCR Central Contractor Registration

C.F.R. Code of Federal Regulations

Common Instructions Common Instructions for Applicants to Department of 

Education Instructions Discretionary Grant Programs 

(Federal Register Vol. 86 FR 3768).

COR Contracting Officer Representative

CPA Certified Public Accountant

D

D&B Dun & Bradstreet

DEOA Department of Education Organization Act

E

ED U.S. Department of Education

EDCAPS Education Central Automated Processing Systems

EDGAR Education Department General Administrative Regulations

EIN Employer Identification Number

EO Executive Order

EPLS Excluded Parties List System

E-Reader Electronic Peer Review System

ERIC Education Resource Information Center
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ERR Entity Risk Review

F

FAC Federal Audit Clearinghouse

FAIN Federal Agency Identification Number

FAPIIS Federal Awardee Performance and Integrity Information 

System

FAR Federal Acquisition Regulations

FAQ Frequently Asked Question

FFATA Federal Funding Accountability and Transparency Act 

FFR Federal Financial Report – Standard Form 425

FMSS Financial Management Support System

FOIA Freedom of Information Act

FR Federal Register

FRC Federal Records Center

FSRS Federal Subaward Reporting System

FWA Federal Wide Assurance

G

GAANN Graduate Assistance in Areas of National Need 

GAN Grant Award Notification

GB Grant Bulletin

GEPA General Education Provisions Act

GPL General Public License

GMPD Grants Management Policy Division

GPRA Government Performance and Results Act

GRS General Records Schedule

H

HEA Higher Education Act

I

ICD Indirect Cost Division

ICR Information Collection Request

ID Identification

IES Institute of Education Sciences

IHE Institution of Higher Education

IPR Interim Performance Report

IQ Information Quality

IRB Institutional Review Board

IRS Internal Revenue Service

ITIN Individual Taxpayer Identification Number
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L

LEA Local Educational Agency

M

MTDC Modified Total Direct Cost

N

NARA National Archives and Records Administration

NFP Notice of Final Priorities

NIA Notice Inviting Applications

NPP Notice of Proposed Priorities

NPRM Notice of Proposed Rule Making

O

OAGRM Office of Acquisition, Grants, and Risk Management

OALJ Office of Administrative Law Judges

OBSS Office of Budget Support Services

OCIO Office of the Chief Information Officer

OCO Office of Communications and Outreach 

OCTAE Office of Career Technical and Adult Education

OELA Office of English Language Acquisition

OESE Office of Elementary and Secondary Education

OF Oracle Financials

OFO Office of Finance and Operations

OGC Office of the General Counsel

OIG Office of Inspector General

OLCA Office of Legislation and Congressional Affairs

OMB Office of Management and Budget

OPE Office of Postsecondary Education

OPEPD/GPO Office of Planning, Evaluation and Policy Development, 

Grants Policy Office 

OS Office of the Secretary

OSERS Office of Special Education and Rehabilitative Services

P

PAM Post Award Monitoring

PCAOB Public Company Accounting Oversight Board

PDL Program Determination Letter

POC Principal Operating Component

PRA Paperwork Reduction Act
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PTIN Preparer Taxpayer Identification Number

R

RMSD Risk Management Services Division

RSD Regulatory Services Division

RPPR Research Performance Progress Report

RQM Regulatory Quality Manual

S

SAM System for Award Management

SCC Strategic Collections and Clearance 

SEA State Educational Agency

SF Standard Form

SOP Standard Operating Procedures

SOW Statement of Work

SPOC State Single Point of Contact

SSN Social Security Number

T

TA Technical Assistance

TIN Taxpayer Identification Number

TRF Technical Review Form

U

USC United States Code (U.S.C.)

UEI Universal Entity Identifier

V

VR Vocational Rehabilitation

W

WWC What Works Clearinghouse