Language Resource Centers (LRC) 

PROGRAM ADMINISTRATION MANUAL (PAM)

International and Foreign Language Education

U.S. Department of Education |Office of Postsecondary Education

400 Maryland Avenue, S.W. |Washington, D.C. 20202

Website | Twitter | YouTube | Newsletter
LRC Program Administration Manual

FY 2022-2025 

Table of Contents 2

Table of Contents

Purpose of the PAM and Contacts........................................................................................................ 3

The Basics: Grant Roles and Responsibilities........................................................................................ 4

Grant Schedule and Continuation Awards............................................................................................ 7

Reporting in the IRIS System ................................................................................................................. 9

LRC Administration Essentials.............................................................................................................10

LRC Travel Guidance............................................................................................................................15

CHEAT SHEETS

Cheat Sheet – LRC Grant Administration............................................................................................18

Cheat Sheet – Fly America Act and Open Skies..................................................................................19

APPENDICES

Appendix A – Glossary of Selected Grant Terms................................................................................21

Appendix B – International Education General Provisions Definitions..............................................28

Appendix C – Government Performance and Results Measures.......................................................29

Appendix D – Financial Management and Drawdowns .....................................................................30

Appendix E – Legislation and Regulation Resources ..........................................................................32

Appendix F – LRC Official Program Citations ......................................................................................33

Appendix G – Fly America and Open Skies .........................................................................................35

Appendix H – Subaward Resources.....................................................................................................39

Appendix I – The Site Visit...................................................................................................................47

Appendix J – Open Licensing and Citing Support................................................................................48

Appendix K – Engage with IFLE Flyer...................................................................................................50
LRC Program Administration Manual

FY 2022-2025 

Purpose of the PAM and Contacts 3

Purpose of the PAM and Contacts

Purpose of the Program Administrative Manual (PAM)

The International and Foreign Language Education (IFLE) Office of the U.S. Department of Education 

administers 11 discretionary grant programs authorized under the Fulbright-Hays Act of 1961 and Title 

VI and Title VII of the Higher Education Act (HEA) of 1965, as amended.

This Program Administration Manual (PAM) for the Language Resource Centers (LRC) program was 

developed to help ensure successful project administration and fiscal accountability throughout the 

duration of the grant.

The program officer and grantees share the responsibility of maintaining compliance. 

The Fiscal Year (FY) 2022-2025 PAM provides information on reporting requirements and schedules, LRC 

administration, and other topics. The FY 2022-2025 PAM offers the most essential information in pages 

3-19 (including one-page “cheat sheets” for program staff on pages 18-19), with appendices offering 

additional detailed information. 

Contacts

IFLE’s Advanced Training and Research Division (ATRD) administers LRC grants. Please feel free to 

contact the LRC program officer with questions, comments and concerns or to seek additional 

information about the administration of your LRC grant.

Assignment Contact Person Email Address Phone Number

Cheryl Gibbs Senior Director of IFLE cheryl.gibbs@ed.gov 202-453-5690

Sarah Beaton ATRD Director sarah.beaton@ed.gov 202-453-7221

Carolyn Collins LRC Program Officer carolyn.collins@ed.gov 202-453-7854
LRC Program Administration Manual

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The Basics: Grant Roles and Responsibilities 4

The Basics: Grant Roles and Responsibilities

IFLE Program Officer Responsibilities

Monitoring project implementation

+ 

Providing technical assistance to grantees on programmatic and fiscal management

= 

Helping to ensure that project goals and objectives are met successfully

Program officers:

□ Review performance reports and external evaluation reports; 

□ Monitor projects to assess compliance; 

□ Make determinations of substantial progress (see Glossary); 

□ Respond to questions and provide guidance on grant management;

□ Process requests (e.g., administrative actions such as project director changes, travel approvals, 

etc.) in a timely manner. 

These tasks are achieved through day-to-day communication with grantees, and through virtual and oncampus site visits.

Institution Responsibilities

The institution (grantee) is the legal entity accountable to the U.S. Government for the use of federal 

funds. The institution must:

□ Comply with the applicable legislation and regulations for the program; 

□ Expend funds in accordance with the program’s allowable costs and the approved application; 

□ Directly supervise project administration; 

□ Use fiscal control and accounting procedures that ensure accountability of federal funds.

Project Director Responsibilities

The Project Director (PD) must: 

□ Ensure that the scope of work described in the funded application’s approved narrative and 

budget is performed; 

□ Exercise proper stewardship of federal funds; 

□ Comply with all legislative and regulatory requirements; 

□ Submit required performance reports that demonstrate and/or measure progress toward the

achievement of project goals. 
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The Basics: Grant Roles and Responsibilities 5

The PD is responsible for communicating with the IFLE program officer to submit requests to: 

□ Transfer funds among direct cost categories (when the cumulative amount of transfers exceeds 

10% of the total project budget for the budget period (fiscal year) – see page 11 for more 

information);

□ Change the scope or the objective(s) of the project;

□ Contract out any of the project activities described in the application;

□ Change the project director or authorized representative/official as listed on the application, 

SF-424, or Grant Award Notification (GAN) document. See page 13 for more information. 

Note: The grantee must notify the program officer in writing if the Project Director is going to be absent 

for a period of more than three months.

Consortium Project Responsibilities

The lead institution is accountable for all partner institutions with regards to reporting, activities, and 

outcomes of the grant. That said, the activities conducted by all institutions in a consortium are equally 

important to the overall project and they complement the training, research, and outreach activities of 

each member institution. The extent to which activities are well-coordinated and communication occurs 

between/among the institutions determines the overall success and effectiveness of the consortium.

IFLE recommends that consortia establish an agreement document to clearly outline the partnership 

and responsibilities of each institution. In a consortium project, the Project Director at the lead 

institution (the institution that receives the Grant Award Notification) is responsible for ensuring that all 

partners conduct their respective activities in compliance with the approved plan; use grant funds in 

accordance with the negotiated revised budget; and submit performance report data and narratives on 

time and in a complete manner. The lead institution, as the direct and primary recipient of IFLE grant 

funds, is accountable to IFLE for the performance of the project, the appropriate expenditure of grant 

funds by all parties, applicable reporting requirements, and all other obligations of the grantee. The lead 

institution is also responsible for sharing information from IFLE with the partner institution(s).

With regards to consortium reporting: The IRIS system will only allow one budget file to be uploaded to 

a performance report. Each institution should submit their budgets on a separate sheet, within one file 

(e.g., two Excel worksheets within one Excel Workbook). 

Subawards

Grantees can establish a subaward with any organization that performs grant-supported research 

activities and shares responsibility with the grantee for administering substantive aspects of the project. 

Directly implementing project activities at another institution does not necessarily constitute a 

subaward. 

For example, providing a faculty stipend to a faculty member at the consortium partner is not a 

subaward. Grantees are responsible for making the correct determinations regarding these

relationships. 
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The Basics: Grant Roles and Responsibilities 6

Each subaward must have a formal written agreement for meeting the administrative, financial, and 

reporting requirements of the grant. IFLE holds grantees accountable for their subawardees' research, 

spending, and reporting actions, which must conform to all terms and conditions of the grant 

award. Subawardees cannot use funds from the grantee to form their own subaward agreements with 

other organizations—no third party or third tier subawards are allowed. Project Directors may only

approve subawardee actions that are consistent with the terms and conditions of the grant.

Grant Management Systems and Technical Support

IFLE requires grantees to use two information technology systems for grant administration and 

reporting purposes. G5 (G5.gov) is used throughout the Department. The G5 system provides access to 

official documentation and financial information for each grant. IFLE also employs the International 

Resource Information System (IRIS) for grant reporting. The Help Desk for each system is responsible for 

providing technical support to users. Program officers do not have access to technical support 

information or tools, they can only assist with programmatic and financial issues.

G5 help is available via the e-mail and phone numbers below. 

• Hours Of Operation: 8:00 AM to 6:00 PM EST, Monday - Friday, except on Federal holidays. 

• Toll-Free: 1-888-336-8930 

• TTY: 1-800-877-8339 

• Local: 202-401-6238

• Email: obssed@servicenowservices.com 

IRIS help is available on the IRIS website. 
LRC Program Administration Manual

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Grant Schedule and Continuation Awards 7

Grant Schedule and Continuation Awards

Project Period and Budget Periods

The project period, also known as the performance period, is the Department-approved timeframe for 

a grantee to complete project activities described in the application. The FY 2022 LRC project period is 

48 months.

The LRC multi-year grant is funded in annual increments (contingent on Congress appropriating funds in 

its fiscal year budget) called budget periods. A single budget period is a 12-month period. The LRC grant 

consists of four budget periods, as indicated in the chart in below.

LRC Budget Periods

FISCAL YEAR BUDGET PERIOD ACADEMIC YEAR SUMMER

2022 8/15/22 - 8/14/23 AY 2022-2023 Summer 2023

2023 8/15/23 - 8/14/24 AY 2023-2024 Summer 2024 

2024 8/15/24 – 8/14/25 AY 2024-2025 Summer 2025 

2025 8/15/25 – 8/14/26 AY 2025-2026 Summer 2026 

Non-Competing Continuation Awards

The new grant award in the first year of the grant cycle is a direct outcome of the competition and 

reflects budgetary conditions in that fiscal year. Funding during subsequent years of the grant cycle is 

contingent upon the availability of funds and the grantees’ success in conducting project activities. 

Non-competing continuation (NCC) awards cover the second, third, and fourth years of the award. NCCs 

are processed after the grantee submits an annual performance report, which grantees are required to

submit according to the schedules on page 9. The assigned program officer must determine that the 

report demonstrates substantial progress to process the NCC award. To determine substantial progress, 

the IFLE program officer will review the report for budget and narrative information supporting the 

objectives of the grant, and for exemplary program or project achievements. Program officers also 

assess elements of risk for the grant award when processing NCC awards.

NCC award amounts are not guaranteed to be the same throughout the grant cycle and can be affected 

by several factors, including changes in congressional appropriations, a determination that substantial 

progress has not been made, or other programmatic or budgetary factors. Once NCC amounts are 

confirmed and communicated by the program officer to the grantee, the grantee is required to submit a 

revised budget reflecting the amount of the continuation award. 
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Grant Schedule and Continuation Awards 8

Risk Management

IFLE staff consider a number of factors when assessing risk and making NCC determinations, including: 

• Designation of the grant or entity as high risk1; 

• Grantee compliance with risk mitigation strategies imposed on the award (in the case of past 

risk citations);

• Excessive drawdowns during the previous budget period;

• Large available balance resulting in a substantial carryover request;

• Frequent turnover of project director position;

• Substantial progress made / on schedule toward achieving grant objectives;

• Required performance reports submitted in accordance with reporting deadlines; 

• Current financial and performance information in G5 and IRIS;

• Progress noted on corrective actions, if applicable;

• Audit findings under 2 CFR § Part 200, Subpart F Audit Requirements; or the institution’s 

response to corrective actions to prior audit findings;

• Grant award history in G5.

Additionally, program staff must consider any issues or concerns, identified through day-to-day 

oversight, routine monitoring, and technical assistance efforts, that might adversely affect a grantee’s 

performance under a continuation award (e.g.; inefficient internal controls, poor oversight of the 

project). 

IFLE program officers will consult with the Department’s Office of the General Counsel (OGC) and ED 

Risk Management Services to employ additional risk mitigation strategies, if needed.

1 “High risk” (see Glossary) is an official Department of Education designation applied in accordance with 2 CFR § 3474.10. Prior to 

making an award, the Department conduct a risk evaluation, described in 2 CFR § 200.206. Specific conditions, described in 2 CFR § 

200.208, may be applied to a grant in response to a review of risk posed by applicants, failure to comply with the general or specific 

terms and conditions of a Federal award, failure to meet expected performance goals, and/or when a grant recipient is not otherwise 

responsible. This designation and any related conditions will be reflected on the Grant Award Notification (GAN).
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Reporting in the IRIS System 9

Reporting in the IRIS System

LRC grantees must submit interim and annual performance reports using the IRIS electronic reporting 

system (https://iris.ed.gov). Performance reports help IFLE staff determine whether the grantee is 

making substantial progress toward meeting the project objectives.

Performance report narratives and data should convey compelling information about grant activities 

and provide evidence of the impact of the grant activities. IFLE advises grantees to put as much care into 

preparing their IRIS reports as they did when preparing their grant applications for the competition. 

IRIS includes instructions and screens for grantees to input data and information about their grant 

activities. In addition to describing the grantee’s achievements for a reporting period, the IRIS 

information demonstrates how a particular program’s projects respond to the Government Performance 

and Results Act (GPRA) measures established for that program to assess overall program performance. 

The Project Director is responsible for reviewing and submitting the performance reports into the webbased International Resource Information System (IRIS). If a grantee fails to submit a performance 

report, the Department will not issue a continuation grant award.

Interim, Annual, and Final Performance Reports

Grantees are required to submit the following reports during the grant cycle. To view the most up-todate reporting deadlines and the content for each report type, refer to the reporting schedule in IRIS. 

Two reports each year, except for year 1: 

• October 15 – fall report (focused on uploading data about projects conducted, publications, 

outreach activities, “actuals” budget showing expenses from prior year) 

• April 15 (except in year 4) – spring report (focused on narrative descriptions of project 

adjustments and how the center is meeting program priorities, proposed budget for next fiscal 

year)

Dates Interim Data Report Due Annual Performance Report Due

Year 1 8/15/2022 – 8/14/2023 no report 4/15/2023

Year 2 8/15/2023 – 8/14/2024 10/15/2023 4/15/2024

Year 3 8/15/2024 – 8/14/2025 10/15/2024 4/15/2025

Year 4 8/15/2025 – 8/14/2026 10/15/2025

No annual performance report 

due in April of Year 4.

FINAL Performance Report and 

Final Financial Status Report

(SF 425) due 11/14/2026

(90 days after end of grant). 
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LRC Administration Essentials 10

LRC Administration Essentials

This section provides the most essential information about the administration of your LRC grant. 

Additional information may be found in the appendices.

Allowable Activities

LRCs must carry out activities to improve the teaching and learning of foreign languages. These activities 

must include effective dissemination efforts, whenever appropriate, and may include — 

• The conduct and dissemination of research on new and improved methods for teaching foreign 

languages, including the use of advanced educational technology;

• The development and dissemination of new materials for teaching foreign languages, to reflect 

the results of research on effective teaching strategies;

• The development, application, and dissemination of performance testing that is appropriate for

use in an educational setting to be used as a standard and comparable measurement of skill 

levels in foreign languages;

• The training of teachers in the administration and interpretation of foreign language 

performance tests, the use of effective teaching strategies, and the use of new technologies;

• A significant focus on the teaching and learning needs of the less commonly taught languages, 

including an assessment of the strategic needs of the United States, the determination of ways 

to meet those needs nationally, and the publication and dissemination of instructional materials 

in the less commonly taught languages;

• The development and dissemination of materials designed to serve as a resource for foreign 

language teachers at the elementary and secondary school levels; and

• The operation of intensive summer language institutes to train advanced foreign language 

students, to provide professional development, and to improve language instruction through 

pre-service and in-service language training for teachers.

All LRC budgets should relate to these activities, in addition to addressing: 

• the absolute priority for activities with a significant focus on the teaching of less commonly 

taught languages (LCTLs), and 

• the competitive preference priority for partnerships with Minority-Serving Institutions (MSIs) 

and community colleges.

Open Licensing Expectations

Unless an exception applies, you are required to openly license to the public grant deliverables created 

in whole, or in part, with Department grant funds. See Appendix J – Open Licensing and Citing Support

for more details.
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LRC Administration Essentials 11

LRC Budgets 

To conduct the allowable activities described above, LRC budgets follow the ED-524 form categories: 

• Personnel

• Fringe Benefits

• Travel

• Equipment (may not exceed 15% of the grant amount)

• Supplies 

• Contractual

• Other

• Indirect Costs (capped at 8%) 

Examples: The costs of operating and maintaining facilities, equipment, and grounds, as well 

as depreciation allowances (“facilities costs”); salaries of administrators and services, such 

as payroll and personnel that benefit Federal programs (“administrative costs”).

• Total Direct Costs

The revised budget (see Glossary) submitted by a grantee and approved by the program officer 

represents the official spending plan for implementing LRC project activities. 

Budget Adjustments (Transferring Money Across Categories) 

Grantees are allowed to adjust their budget plans without prior approval, as long as the revisions do not 

materially alter the scope of project activities that the budget supports and as long as the total 

amount of money transferred is under 10% of the total budget for the grant period. Each LRC was

selected to receive FY 2022-2025 funding based on the particular set of activities proposed in the grant 

application that was read and scored during the competitive peer review process. Budget revisions, 

therefore, must not significantly alter the scope of those activities and expectations. 

Consider: If you made this budget adjustment in your original grant application, would your application 

be materially different?

Grantees are allowed to transfer funds between major line items 

provided that the cumulative transferred amount does not exceed 

10% of the total budget for that budget period (grant year). 

Example: If the total grant amount for the fiscal year is $180,000, 

the cumulative amount transferred between line items 

during the fiscal year must not exceed $18,000.

For transfers exceeding the 10% threshold, grantees must obtain prior 

written approval from the IFLE program officer.

To obtain prior approval, the Project Director should submit a brief written justification to the IFLE 

program officer explaining why the budget transfer is needed to conduct the project. The justification 
LRC Program Administration Manual

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LRC Administration Essentials 12

should describe how the transfer is allowable, allocable, and reasonable in meeting the objectives of the 

approved plan, and make clear that it does not materially alter the project’s overall scope. It is the 

grantee’s responsibility to ensure that the cumulative transferred amount does not exceed the 10% 

threshold in each budget period.

Note: Program officers are allowed up to 30 days to respond (e.g., approve, disapprove, request 

more information). Although a 30-day timeframe is allowed, program officers usually review 

requests sooner.

Financial Management and Drawdowns

Grantees must follow the federal requirements for financial management and cash drawdowns in 2 CFR 

§ 200.302. See Appendix D for detailed information.

Carrying Over Unobligated Balances

Grantees are permitted to carry forward unobligated LRC balances to subsequent funding periods 

without obtaining prior approval from ED.2 IFLE recommends discussing your carryover amount with 

your IFLE program officer. Grantees are required to report on carryovers in the IRIS annual report.

No-Cost Extension (Time Extension)

Grantees may request a one-time no-cost extension (NCE) of up to 12 months before the award’s 

expiration date. The grantee must submit a written request – including supporting reasons and revised 

expiration date – to the program officer at least 10 days before the original end date of the award. This 

one-time extension may not be applied merely for the purpose of using unobligated balances.

The NCE request must include the following: 

• PR/Award number; 

• Description of activities to be conducted during the extension period; 

• Explanation(s) for the inability to complete activities during the original performance period; 

• Funds to be used during the extension period; 

• Proposed new end date for the grant. 

If approved, the end date on the grant will be updated in IRIS and G5, and a revised Grant Award 

Notification will be issued by G5 reflecting the new project end date.

2 Title 2 CFR § 200 of the OMB “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” 

waives the prior approval procedures for carryover.
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LRC Administration Essentials 13

Change of LRC Project Director

The Project Director (see Glossary) plays an important role in grant administration. The Project Director 

identified in the GAN must be the individual currently assigned to oversee the grant project.

You must notify IFLE when the Project Director changes permanently or the Project Director is 

temporarily replaced by another individual during an extended absence (such as during a sabbatical or 

health emergency), so a program officer can perform the necessary steps to vet the new Project Director 

according to ED’s practices, register this change in G5 and IRIS, and issue a new GAN. This process is not 

complete until the new Project Director receives an electronic copy of the new GAN, which will be 

accessible in G5. Program officers may interpret the inability to contact a Project Director, frequent 

changes of Project Director or the nomination an ineligible individual as a new Project Director for a 

grant as potential evidence of increased risk for that grant.

To request a change of Project Director, email your program officer with a brief explanation and a copy 

of the CV for the new Project Director. If this message is sent by someone other than the current 

(outgoing) Project Director, the current Project Director and/or the Authorized Representative listed on 

the GAN must be copied on the message.

Adding and Updating LRC Grant Personnel in IRIS

The Project Director is responsible for periodically updating all personnel listed for the grant in IRIS. IFLE 

recommends that Project Director and their colleagues review the listed personnel at least once a year. 

Program officers use this information to contact grant personnel for matters related to grant oversight 

and administration. Contact the IRIS Help Desk for detailed guidance on adding or updating personnel.

Travel Costs and Approvals

Allowable Costs for Travel

Federal funds can be used to pay for airfare, hotels, meals, and incidentals for faculty and staff

members’ travel related to approved LRC activities and faculty professional development. Examples of 

the purposes of travel may include: 

• library acquisitions,

• establishing institutional linkages,

• course development and research, 

• presentations at conferences that are directly related to the center’s area of expertise, 

• professional development.

LRC funds can cover the travel expenses of persons other than the institution’s faculty and staff as long 

as the travel is directly related to an LRC budget activity and the scope of the grant. LRC funds cannot be 

used to support student travel. 
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LRC Administration Essentials 14

General Travel Guidance

• Domestic travel within the scope of approved LRC activities does not require approval by the

IFLE program officer. Expenses cannot exceed allowable rates set by the grantee institution or

the General Services Administration (GSA)3. 

• All international travel expenses covered with LRC funds must be pre-approved by the IFLE 

program officer by submitting a Travel Approval Request (TAR) in IRIS at least 30 days prior to 

planned travel. Per diem expenses cannot exceed the foreign per diem rate set by the 

Department of State, and all flights purchased with federal funds must comply with the Fly 

America Act or an Open Skies Agreement. 

• No travel may occur after the end date of the grant. 

See page 16 for more detailed information about travel and completing a TAR. 

3 U.S. territories are covered by the per diem rates set by the Department of Defense. 
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LRC Travel Guidance 15

LRC Travel Guidance

Travel Costs and Approvals

Federal funds can be used to pay for airfare, hotels, meals, and incidentals for travel related to approved 

grant activities. Grantees must request any required pre-approvals by submitting a Travel Approval 

Request (TAR) in IRIS.

International Travel

All international travel expenses covered with grant funds must be pre-approved by the IFLE program 

officer. 

IFLE does not approve retroactive travel. Flights covered by federal funds must comply with the Fly 

America Act or an Open Skies Agreement (see Appendix G – Fly America and Open Skies). Even if federal 

funds are only paying for the international hotel, the request must be pre-approved. Rates for hotels, 

meals, and incidentals cannot exceed the foreign per diem rate set by the Department of State. 

Expenses exceeding the Department of State rates must be paid for by other sources.

LRC funds may cover visas, the costs of vaccinations, and travel health insurance as required for the 

health and safety of the traveler.

Domestic Travel

Domestic travel within the scope of approved LRC activities does not require approval by the IFLE 

program officer.

Travel expenses for hotels, meals, and incidentals in the 50 U.S. states should not exceed the per diem 

rate set by the institution or the General Services Administration (GSA).4 The pre-tax hotel rate should 

be equal to or less than the GSA rate, and the allowance for meals and incidentals should not exceed the 

GSA rate. Any expenses exceeding GSA rates should be paid for by other sources. 

Car Travel

If travel occurs by car, the reimbursement should not exceed the privately-owned vehicle rate

established by GSA.

Travel after the End of the Grant Period

According to 34 CFR § 75.707, funds required for travel are obligated at the time when travel is taken, 

not at the time that the fare is purchased. As a result, the return date for travel cannot be after the end 

4 U.S. territories are covered by the per diem rates set by the Department of Defense. 
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LRC Travel Guidance 16

date of the four-year duration of the grant’s performance period. A return date after this date is 

allowable only if a no-cost extension has been granted.

Travel Approval Requests (TARs)

An approved Travel Approval Request (TAR) is required for international travel supported by LRC grants.

Requests to spend federal funds on LRC travel must be submitted in IRIS at least 30 days before the 

date of travel and approved prior to making any non-refundable purchases or beginning travel. Program 

officers need this time to review the TAR, consult with federal partners, address travel warnings and

other safety concerns, and return disapproved TARs for revision. 

IFLE does not make retroactive approvals. Grantees should not purchase tickets before receiving 

approval, but travelers may make tentative, non-binding reservations. Non-refundable purchases are 

not an acceptable justification for approving unallowable travel expenses.

A complete TAR includes: 

• A description of the trip’s purpose, including the trip’s connection to approved grant activities.

• A certification from the grantee that the travel is compliant with the Fly America Act or an Open 

Skies Agreement. Grantees are responsible for verifying that travel is compliant. 

• An itemization of costs under “explanation of expenditures” that reflects appropriate allowable 

rates, such as GSA per diem or State Department foreign per diem rates. Grantees should break 

out expenses by category, including itemizing lodging expenses separately from expenses for 

meals and incidentals. Example: 

Roundtrip Airfare: Miami-São Paolo = $978

Airport transfers: $200

Hotel in São Paulo – $282/night x 2 nights = $564

Meals/incidentals in São Paulo – $126/day x 2 days = $252

• If the flight qualifies under an Open Skies Agreement or other exception, the submitter should 

include an explanation in the comments section of how the flight meets the exception.

Note: Due to security concerns, we do not allow travel to certain parts of the world using Title VI 

funding. Because security situations are often fluid, it is not possible for us to generate a stable list of 

countries to which we do not allow travel. IFLE program officers closely monitor the security situations 

throughout the world and decide together, with reference to the State Department’s travel advisory 

pages, where travel will be allowed and where it will not. Contact your program officer if you have any 

doubts or questions about the possibility of travel to certain countries and keep in mind that travel 

approvals may be revoked if security situations change.
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CHEAT SHEETS 17

CHEAT SHEETS
LRC Program Administration Manual

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Cheat Sheet – LRC Grant Administration 18

Cheat Sheet – LRC Grant Administration 

• Financial management and drawdowns: Grantees must follow the federal requirements for 

financial management and cash drawdowns in 2 CFR § 200.302. See page 30 for more information. 

• Budget adjustments: Grantees can adjust their budget plans without prior approval, as long as:

o the revisions do not materially alter the scope of project activities, AND 

o the amount transferred between categories does not exceed 10% of the total budget for 

that budget period. 

Example: Total FY budget is $180,000. Cumulative amount transferred during the 

FY may not exceed $18,000 without prior approval.

For transfers exceeding the 10% threshold, grantees must obtain prior written approval from the 

IFLE program officer.

When you have a substantial change to a project activity or to your overall budget, please send a 

revised budget to your IFLE program officer for official approval.

• Travel: LRC funds may be used to cover travel expenses related to approved LRC activities.

o Domestic travel (within the United States) does not require prior approval.

o International travel requires prior grantee submission and IFLE program officer approval of a 

Travel Approval Request (TAR) in IRIS.

- International flights covered by LRC funds must comply with Fly America/Open Skies. 

- All costs must be itemized in the “comments” section using allowable rates.

o Allowable rates: Lodging and meals/incidentals expenses covered by LRC funds must comply 

with the allowable rates set by the relevant U.S. government authority:

- U.S. states: General Services Administration (GSA) per diem rates

- U.S. territories: Department of Defense per diem rates

- International: Department of State per diem rates

• Carryover: Grantees may carry forward unobligated LRC balances to subsequent funding periods 

within the grant cycle without obtaining prior approval from ED.

o IFLE still recommends discussing your carryover amount with the IFLE program officer. 

o Grantees are required to report on carryover in the IRIS annual report.

• Time extension: Grantees may request a one-time no-cost extension (NCE) of up to 12 months after 

the award’s original expiration date. The grantee must submit a written request to the IFLE program 

officer at least 10 days before the original end date of the award. IFLE encourages grantees to 

submit requests earlier than this if possible. 
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Cheat Sheet – Fly America Act and Open Skies 19

Cheat Sheet – Fly America Act and Open Skies

In short, the Fly America Act means that if federal funds pay for air travel, the traveler must use a U.S. 

air carrier whenever possible, to the greatest extent possible. Cost and convenience are not allowable 

exceptions. There are some exceptions to the rule based on Open Skies partnerships and extremely 

inconvenient circumstances; those are further explained in Appendix G – Fly America and Open Skies. 

The following is an Open Skies cheat sheet to help you quickly determine when you may be eligible to 

use a European Union, Japanese, or Swiss air carrier. For more detailed information, visit the appendix.
LRC Program Administration Manual

FY 2022-2025 

APPENDICES 20

APPENDICES
LRC Program Administration Manual

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Appendix A – Glossary of Selected Grant Terms 21

Appendix A – Glossary of Selected Grant Terms

A list of commonly used terms and acronyms in the administration of discretionary grants, including 

grants under the Language Resource Centers Program, is below.

• Administrative action: A post-award administrative request by a grantee to modify the terms 

and conditions of the original grant. An administrative action can be monetary or non-monetary 

and may require prior approval from the U.S. Department of Education (“the Department”).

• Administrative regulations: Regulations that implement 1) guidance in 2 Code of Federal 

Regulations (CFR) Part 200 of the OMB “Uniform Administrative Requirements, Cost Principles, 

and Audit Requirements for Federal Awards,” which apply to the administration of all federal 

grants and cooperative agreements; 2) presidential executive orders (if regulation is necessary); 

3) legislation affecting all applicants for or recipients of federal grants and cooperative 

agreements; and 4) the Department’s specific requirements for the award and management of 

grants.

• Allocable cost: Cost that can be traced to specific activities of a grant project.

• Allowable costs: A cost incurred by a grantee that is necessary and reasonable for the 

performance of the award; 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 

Notification as to types or amount of cost items; consistent with the grantee’s policies and 

procedures that apply uniformly to both Federally financed and other activities of the grant; 

determined in according with generally-accepted accounting principles; and not included as a 

cost in any other Federally financed grant (unless specifically authorized by statute). Allowable 

cost requirements for Department of Education grants can be found in the Uniform Guidance (2 

CFR § 200), federal accounting standards, and other authoritative sources.

• Appropriations statute (legislation): A statute (legislation) 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. 

Grantees should preserve this documentation throughout the lifecycle of a grant.

• Approved budget: The budget submitted by the grantee and any revisions for which approval is 

necessary by the program office and which have been approved. The approved budget includes 

cost items for Federal funds and may include cost items for non-Federal funds, if cost sharing is 

required or volunteered (34 CFR § 75.232). Also see Revised Budget.

• Assistance Listing Number (ALN) [formerly CFDA number]: The identifying number for a federal 

financial assistance program. Each ALN has a two-digit prefix to identify the federal agency that 

administers the program (84 is the prefix for the Department), followed by a three-digit code 

unique to the authorized program (e.g., 84.229A Language Resource Centers Program). ED 

programs begin with 84.
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Appendix A – Glossary of Selected Grant Terms 22

• Assurances: A list 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 (2 CFR § 200.208).

• Audit finding: A conclusion about a monetary or non-monetary matter related to an auditor’s 

examination of a grantee’s organization, program, activity, or function. Audit findings frequently

identify problems with an organization’s grant expenditures and/or compliance with other grant 

requirements and provide recommendations for corrective action in order to prevent their 

recurrence. 

• Authorized representative: The individual entrusted by the applicant/grantee organization to 

sign the application and the applicable assurances and certifications on 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.

• Authorizing statute (legislation): A statute (legislation) passed by Congress that establishes or 

continues, in the case of reauthorization, an activity such as a grant program either indefinitely 

or for a specified period of time. An authorizing statute is generally a prerequisite for 

appropriations. 

• Budget period: An interval of time into which a project period is divided for budgetary purposes, 

usually 12 months (34 CFR § 77.1(c)). 

• Budget revision: A modification to a grantee’s budget. A grantee is allowed to revise its budget 

by moving funds from one budget category to another without obtaining prior approval, 

provided that the reallocated amount does not exceed 10% of the total direct costs of the grant. 

• Carry over: Unexpended funds from one budget period used in a subsequent budget period. 

Funds in a grantee’s G5 account are disbursed on a “first-in/first-out” basis; therefore, carryover funds from year one of the project period are unlikely to be available for use in year three.

• CFDA number: See Assistance Listings Number (ALN). 

• 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 G5 (see 2 CFR § 200.344). The grantee is required to 

submit all financial, performance, and other reports as required by the terms and conditions of 

the grant no later than 90 calendar days after the end date of the performance period. 

• Code of Federal Regulations (CFR): 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. An 

online version is available for consultation at the Electronic Code of Federal Regulations (eCFR). 

• 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 CFR § 200 Subpart E. 

• Continuation award (non-competing): A grant made to a recipient following the first budget 

period of a multi-year project, which extends the funding for another budget period within the 
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Appendix A – Glossary of Selected Grant Terms 23

approved project period, contingent upon the grantee’s submission of required reports, 

substantial progress, and a determination that continuation funding is in the best interest of the 

Federal government. 

• Direct costs: Costs in a grant project that are identified specifically as part of a particular activity 

or cost objective. Examples of direct costs include compensation of employees for time devoted 

to the performance of grant activities; cost of materials acquired, consumed, or expended 

specifically for the purpose of the grant; and travel expenses incurred specifically to carry out 

the activities of the project.

• ED: The acronym for the U.S. Department of Education (not DOE).

• Education Department General Administrative Regulations (EDGAR): 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 (CFR) (defined above), as described here: 

Education Department General Administrative Regulations (EDGAR). 

• Excessive drawdown: An excessive drawdown occurs when a grantee makes a drawdown in 

excess of its immediate cash needs. The Department’s Office of the Chief Financial Officer and 

IFLE program officers monitor grantee accounts in G5 to determine instances of excessive 

drawdowns using the following thresholds:

o First quarter: more than 50 percent of the funds for the budget period have been drawn 

down by the end of this quarter;

o Second quarter: more than 80 percent of the funds for the budget period have been 

drawn down by the end of this quarter;

o Third quarter: 100 percent of the funds for the budget period have been drawn down by 

the end of this quarter. The program officer will contact the grantee immediately after 

the excessive drawdown is identified to inquire about the excessive drawdown and will 

allow the grantee fourteen days to resolve the issue. The program officer will notate the 

resolution of the excessive drawdown in G5 and will include all documentation in the 

grant official file.

o If a grantee’s account is flagged for an excessive drawdown, your program officer will 

contact you to request a written explanation as to why the excessive drawdown 

occurred and how the issues that caused it to have been resolved.

• Federal Financial Report (SF-425): 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. Usually required at the end of the project period along with a final performance 

report. 

• 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 
LRC Program Administration Manual

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Appendix A – Glossary of Selected Grant Terms 24

is encouraged but not required to address. Applications addressing invitational priorities receive 

no preference over applications that do not meet the priority (34 CFR § 75.105).

• Government Performance and Results Act (GPRA) of 1993: GPRA is a public law that was 

passed by Congress in 1993, revised by the Government Performance and Results 

Modernization Act of 2010 (GPRA) was enacted to improve stewardship in the Federal 

Government and to link resources and management decisions with program performance. GPRA 

requires that all federal departments (not grantees) do the following:

o develop a strategic plan specifying what they will accomplish over a 3- to 5-year period;

o set performance targets related to their strategic plan on an annual basis;

o report annually the degree to which the targets set in the previous year were met;

o conduct regular evaluations of their programs and use the results to explain their 

successes and failures based on the performance monitoring.

• 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 (34 CFR § 75.235).

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 34 

CFR § 77.1(c). 

• Grant management system (G5, G5.gov): A financial subsystem that is part of the Education 

Department Central Automated Processing System (EDCAPS). G5 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. Also see International Resource 

Information System (IRIS).

• 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 CFR § 200.208; for ED’s 

authority to designate a grantee as high risk, see 2 CFR § 3474.10).

• Indirect costs: Costs an organization incurs for common or joint objectives that cannot be 

readily and specifically identified as part of a specific grant project or other institutional activity

(see 34 CFR § 75.560 and 76.560).

• Indirect cost rate: A percentage established by a federal agency for a grantee organization, 

which the grantee uses to compute the amount of grant funding (in dollars) that it uses to 

reimburse itself for the indirect costs of a grant project. 

• Indirect cost rate agreement: A formalized written and signed agreement between a recipient 

and the cognizant federal agency that specifies the treatment of indirect costs. The agreement 

includes the approved rate(s), applicable fiscal year, and specific treatment of certain items. The 

rates and cost treatment laid out in the agreement are accepted and used by all federal agencies 
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Appendix A – Glossary of Selected Grant Terms 25

unless prohibited or limited by statute. Indirect cost reimbursement is limited to the grantee’s 

actual indirect costs, as determined in its indirect cost rate agreement, or eight percent of a 

modified total direct cost base, whichever amount is less (34 CFR § 75.562(c)(3)-(4) and 2 CFR § 

200.414). 

• Indirect cost type: The program indirect cost type identifies the type of indirect cost permitted 

under the program (Restricted, Unrestricted, or Training).

• International Resource Information System (IRIS): The web-based database and reporting 

system specifically designed for the International and Foreign Language Education (IFLE) office 

Fulbright-Hays and Title VI discretionary grant programs. IRIS is a password-protected reporting 

system that captures and reports annual and final performance reports from IFLE grantees. IRIS 

also contains publicly accessible current and historical information about the programs 

administered by IFLE. Also see Grant Management System.

• Monitoring: Monitoring is the regular and systematic assessment of 1) how well a grant is being 

implemented and achieving outcomes, 2) the degree to which it is meeting established 

measures, and 3) whether it is complying with statutory requirements, program regulations, 

polices and fiscal requirements.

• Monitoring and Technical Assistance Plan: A plan that provides standards and serves as a guide 

for monitoring and for providing technical assistance for each grant program. The plans are 

maintained within the IFLE office.

• Office of Management and Budget (OMB): A branch of the Executive Office of the President. 

OMB oversees and coordinates the administration’s procurement, financial management, 

information collection, and regulatory policies, including grant policies and procedures.

• OMB circulars: Administrative policy documents issued by OMB that provide guidance on grant 

administration. Many OMB circulars were revised in 2014 and codified in Title 2, Part 200 of the 

Code of Federal Regulations. (2 CFR § 200, the “Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards”).

• Open licensing requirement: The expectations for openly licensing most grant deliverables, as 

explained in 2 CFR § 3474.20. 

• Performance measure: A quantitative indicator, statistic, or metric used to gauge program or 

project performance and used as a unit for measuring outcomes.

• Performance report: A report of the specific activities conducted by the grantee during the 

budget or project period.

• Performance target: A level of performance that a grantee seeks to meet during a project or as 

a result of a project.

• Program regulations: Regulations that implement legislation authorizing a specific grant 

program. Program regulations generally include applicant and participant eligibility criteria, 

allowable activities, and program selection criteria. 

• PR/Award number: The identifying number for a discretionary grant. It includes the program 

identifier, the fiscal year for the competition, and the number assigned to the project, e.g., 

P229A220018, means a Language Resource Centers program grant awarded in fiscal year 2022

with grant number 18. 
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Appendix A – Glossary of Selected Grant Terms 26

• Project director (PD): An individual designated by the grantee to direct the project or program 

being supported by a grant. The PD is responsible and accountable to officials of the grantee 

organization for the successful outcome of the project, program or activity. The PD is commonly 

identified as the Principal Investigator (PI) by some grantees.

• Project materials: A copyrightable work developed with funds from a grant issued by the 

Department. (34 CFR § 75.622). These materials must include required statements as described 

in 34 CFR § 75.620. 

• Project period (performance period): The period established in the award document during 

which Federal sponsorship begins and ends (see 34 CFR § 77.1(c) and “Period of Performance” 2 

CFR § 200.77). During this period, the Department will fund a grant project and authorize a 

grantee to conduct the approved work of the project as described in the application. When the 

Department awards a multi-year grant, it usually obligates funds for the first budget period, and 

explains that funds for the subsequent budget periods are contingent upon certain conditions 

such as available funds and the grantee’s progress towards meeting the project’s objectives.

• 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 (see the Federal cost principles in 2 CFR § 200 Subpart E).

• Revised budget: The selected applicant’s budget plan that incorporates any budgetary changes 

and/or cost items that have been reduced or deleted during the Department’s budget review 

and negotiation before the initial Grant Award Notification is issued. Also see Approved Budget.

• 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.

• 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 34 CFR § 75.253). The annual 

performance reports should reflect evidence that the grantees’ activities are consistent with the 

plans and objectives to which the Department and the grantee have agreed.

• Supplies: All tangible personal property other than those described as Equipment, which 

generally refers to tangible personal property (including information technology systems) having 

a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the 

lesser of the capitalization level established by the non-Federal entity (grantee institutions) for 

financial statement purposes, or $5,000. (2 CFR § 200.201, 200.313, and 200.314).

• Time extensions (no-cost time extension, no-cost extension, NCE): 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 CFR § 200.308 and 

34 CFR § 75.261). Time extensions for these programs occur at the end of the 48-month project 

period. It allows the grantee additional time beyond the approved project end date (i.e., beyond 

August 14, 2026) to complete the approved project activities. A grantee may use grant funds 

during the time extension for activities that could not be conducted by the project end date. 

Time extension funds must not be used to conduct entirely new activities.
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Appendix A – Glossary of Selected Grant Terms 27

• Travel costs: The Uniform Guidance defines “travel costs” as the expenses for transportation, 

lodging, subsistence, and related items incurred by employees who are in travel status on 

official business. 

• Uniform Administrative Regulations (“Uniform Guidance”): Regulations and requirements 

codified at 2 CFR § Part 200, “Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards”. Also referred to as “Uniform Guidance,” it includes certain 

regulations formerly covered by the Education Department General Administrative Regulations

(EDGAR, addressed above), parts 74 and 80, and supersedes and streamlines requirements from 

OMB Circulars A-21, A-87, A-110, A-122, A-89, A-102, and A-133, and the guidance in Circular A50 on Single Audit follow-up. More information is available here: Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards | U.S. Department of 

Education. 

• Unique Entity Identifier (UEI): A number used to identify a specific commercial, nonprofit, or 

Government entity. The UEI is used within SAM.gov as a primary key to uniquely identify an 

entity or part of an entity. The UEI replaces the DUNS number.
LRC Program Administration Manual

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Appendix B – International Education General Provisions Definitions

28

Appendix B – International Education General 

Provisions Definitions

The following definitions are found in 34 CFR § 655.4 and § 669.5 and are applicable to the Language

Resource Centers Program:

• Consortium of institutions of higher education means a group of institutions of higher 

education that have entered into a cooperative arrangement for the purpose of carrying out a 

common objective, or a public or private nonprofit agency, organization, or institution 

designated or created by a group of institutions of higher education for the purpose of carrying 

out a common objective on their behalf.

• Institution of higher education means, in addition to an institution that meets the definition of 

section 101(a) of the Higher Education Act of 1965, as amended, an institution that meets the 

requirements of section 101(a) except that (1) it is not located in the United States, and (2) it 

applies for assistance under title VI of the Higher Education Act of 1965, as amended, in 

consortia with institutions that meet the definitions in section 101(a).

• Language Resource Center means a coordinated concentration of educational research and 

training resources for improving the nation's capacity to teach and learn foreign languages.
LRC Program Administration Manual

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Appendix C – Government Performance and Results Measures

29

Appendix C – Government Performance and Results 

Measures

GPRA Measures

The Government Performance and Results Act (GPRA) of 1993, revised by the Government Performance 

and Results Modernization Act of 2010, was enacted to improve stewardship in the Federal Government 

and to link resources and management decisions with program performance.

The Department is required by GPRA to submit data on grantee performance to the Office of 

Management and Budget. The information provided by grantees in their performance reports submitted 

via the IRIS reporting system will be the source of data for reporting on the GPRA measures. The 

Department has developed (and the Office of Management and Budget has approved) the following 

GPRA measures to evaluate the overall success of the LRC grant program:

1. Percentage of LRC products or activities judged to be successful by LRC customers with respect 

to quality, usefulness and relevance.

2. Percentage of LRC products judged to be successful by an independent expert review panel with 

respect to quality, usefulness and relevance.

3. Efficiency: Cost per LRC project that increased the number of training programs for K-16 

instructors of LCTLs.

Note: IFLE will be able to calculate the Efficiency Measure based on the LRC reports submitted in IRIS. 
LRC Program Administration Manual

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Appendix D – Financial Management and Drawdowns 30

Appendix D – Financial Management and Drawdowns

Grantees must follow the federal requirements for financial management and cash drawdowns in 2 CFR 

§ 200.302. Every evening, G5 compares drawdown activity against preset thresholds and identifies 

grants that have atypical drawdown patterns (i.e., excessive or insufficient drawdowns). G5 also

identifies route payment, reimbursement, and stop payment flags; program staff review and address 

these with grantees as appropriate.

LRCs must: 

• Draw down only as much cash as is necessary to meet the immediate needs of the grant project;

• Keep to a minimum the time between drawing down the funds and paying them out for grant 

activities; and

• Return/reimburse the Government for all interest earned on grant funds deposited in interestbearing bank accounts.

• Spend down as much awarded grant funding as possible (following approved project proposal 

and budget) to minimize the amount to be returned to the Treasury at the end of the grant.

Staff are advised to:

• Coordinate the timing of drawdowns with prior internal clearances (e.g., by boards, directors, or 

other officials) for immediate cash needs so that funds do not stay in a bank account for 

extended periods of time while waiting for approvals; 

• Continuously monitor fiscal activity (grant drawdowns and payments) on a continuous basis;

• Plan carefully for cash flow during the budget period and review cash requirements before each 

drawdown; and

• Pay for project activities as soon as practical after receiving cash from the Department.

The Department will contact a grantee who has drawn down:

• 50% or more of the grant in the first quarter;

• 80% or more in the second quarter; and/or 

• 100% of the cash in the third quarter of the budget period.

Note: Amounts under these thresholds could still represent excessive drawdowns for particular 

grant activities in any quarter. Grantees who draw down excessive cash will be required to 

return excess funds to the Department, along with any associated earned interest, until the 

money is needed to pay for activities.

If you need assistance with returning funds and interest, please contact the Department's G5 Hotline by 

calling 1-888-336-8930. 

Grantees who do not follow federal cash management requirements and/or who consistently appear on 

the Department's reports of excessive drawdowns could be:

• subject to specific award conditions or designated as "high-risk" (see Glossary) grantees, which 

could mean being placed on a "cash-reimbursement" payment method (i.e., a grantee would 
LRC Program Administration Manual

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Appendix D – Financial Management and Drawdowns 31

have to pay for grant activities with its own money and then wait for reimbursement from the 

Department afterwards);

• subject to further corrective action;

• denied selection for funding on future Department of Education grant applications (34 CFR §

75.217(d)(3)(ii)); and/or

• debarred or suspended from receiving future federal awards from any executive agency of the 

Federal Government.

All project directors, staff, and authorized representatives are urged to read 2 CFR § Part 200.305 to 

learn more about federal requirements related to grant payments and to determine how to apply these 

requirements to any sub-grantees. Grantees are urged to make copies of this guidance and share it with 

all affected individuals within the organization.
LRC Program Administration Manual

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Appendix E – Legislation and Regulation Resources 32

Appendix E – Legislation and Regulation Resources 

Program Legislation: Title VI, Part A, Sections 601 and 603 of the Higher Education Act of 1965, as 

amended

International Education Programs General Provisions: 34 CFR § 655

LRC Regulations: 34 CFR § 669

20 U.S.C. Section 1123

20 U.S.C. Sections 1132-1137

Education Department General Administrative Regulations (EDGAR)

Uniform Guidance (2 CFR § 200)
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Appendix F – LRC Official Program Citations 33

Appendix F – LRC Official Program Citations

The Language Resource Centers Program makes awards for the purpose of establishing, strengthening, 

and operating centers that serve as resources for improving the nation's capacity for teaching and 

learning foreign languages effectively.

Notice Inviting Applications

Federal Register: Fiscal Year 2022 Applications for New Awards; Language Resource Centers Program

This notice contains general information that remains relevant throughout the grant cycle, including a 

list of applicable regulations and award administration information.

Grant Priorities

Implementation of Priorities 

• All grantees must meet the absolute priority for activities with a significant focus on the 

teaching and learning of less commonly taught languages (any language other than French, 

German, and Spanish). 

• If a grantee proposed to implement the competitive preference priority in its application, it 

must carry out those proposed activities. When revising budgets, the activities for which the 

grantee received competitive preference priority points must not be eliminated. 

• Grantees will report on their progress implementing the priorities in their IRIS reports.

Absolute Priorities

“Applications that propose activities with a significant focus on the teaching and learning of any modern 

foreign languages except French, German, and Spanish.” 

(Source: LRC program regulations, 34 CFR § 669.22(a)(2))

Competitive Preference Priority

“Projects that will be implemented by or in partnership with one or more of the following entities:

(1) Community colleges (as defined in the Notice Inviting Applications).

(2) Historically Black colleges and universities (as defined in the Notice Inviting Applications).

(3) Tribal Colleges and Universities (as defined in the Notice Inviting Applications).

(4) Minority-serving institutions (as defined in the Notice Inviting Applications).” 

(Source: Priority 2 subpart (b), Secretary’s Final Supplemental Priorities and Definitions for 

Discretionary Grant Programs published in the Federal Register on December 10, 2021 (86 FR 

70612))
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Appendix F – LRC Official Program Citations 34

Definitions: The definitions below are from the Supplemental Priorities, and are the definitions that 

appear in the Notice Inviting Applications. 

Community college means “junior or community college” as defined in section 312(f) of the 

Higher Education Act of 1965, as amended (HEA).

Historically Black Colleges and Universities means colleges and universities that meet the criteria 

set out in 34 CFR § 608.2.

Minority-Serving Institution (MSI) means an institution that is eligible to receive assistance under 

sections 316 through 320 of part A of title III, under part B of title III, or under title V of the HEA.

Tribal College or University has the meaning ascribed it in section 316(b)(3) of the HEA.

Note: The institutions designated eligible under title III and title V may be viewed at the following 

link: www2.ed.gov/about/offices/list/ope/idues/eligibility.html
LRC Program Administration Manual

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Appendix G – Fly America and Open Skies 35

Appendix G – Fly America and Open Skies

The Fly America Act (49 U.S.C. 40118) generally provides that foreign air travel funded by Federal 

government money may only be conducted on U.S. flag air carriers. Tickets paid for with federal funds 

must be ticketed with a U.S. flag carrier code. 

• A "U.S. flag air carrier" is an air carrier that holds a certificate under 49 U.S.C. 41102 but does 

not include a foreign air carrier operating under a permit. A carrier code is made up of the letters 

that appear before the flight number (e.g., “UA 784” for United Airlines flight 784).

We understand that U.S. flag carriers are not always available to the final destination; however, a U.S. 

flag carrier must be used to the furthest destination possible. Additionally, a grantee must fly on a U.S. 

airline even if a foreign airline would be less expensive, provide preferred routing, or be more 

convenient. 

There are limited circumstances under which exceptions can be made for travelers to use non-U.S. air 

carriers (see below).

If grantees choose to use non-federal funds to pay for an international flight, they do not need to 

comply with Fly America/Open Skies.

Code Sharing and the Fly America Act

“Code sharing” is when a ticket is issued by one airline but operated by another. When a U.S. flag carrier 

leases seats on a foreign carrier and the ticketing code is from the U.S. airline, it meets the Fly America 

Act requirements. For example, on a flight from San Francisco, CA to Hong Kong:

• American Airlines flight 6117 (ticketed as AA6117), operated by Cathay Pacific Airways, is 

considered a U.S. carrier.

• Cathay Pacific Airways flight 873 (ticketed as CX873) is not considered a U.S. carrier even though 

it is the same flight as listed above.

Exceptions to the Fly America Act

The Federal Travel Regulation allows for limited exceptions to the Fly America Act. Use of a non-U.S. 

airline is permissible when:

1. The transportation is provided under a bilateral or multilateral air transportation agreement, 

such as the Open Skies Agreement (see next section).

2. The use of a foreign air carrier is determined to be a matter of necessity—mission, nonavailability of flight, medical, safety/terrorist threats, non-availability of authorized class of 

service. 
LRC Program Administration Manual

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Appendix G – Fly America and Open Skies 36

3. There is no U.S. flag carrier service on a particular leg of the route. Under this exception, a U.S. 

carrier must be used as far as possible, and a foreign carrier is only allowed from the nearest 

interchange point.

4. A U.S. flag carrier involuntarily reroutes travel on a foreign carrier.

5. Short-distance travel on a foreign carrier is allowed when the travel on the foreign carrier would 

be less than 3 hours, and the equivalent travel on a U.S. carrier would at least double travel 

time. 

6. If a U.S. flag carrier offers nonstop service from origin to destination, the grantee must fly the 

U.S. carrier unless such use would extend travel time (including delay at origin) by 24 hours or 

more. 

7. If a U.S. flag carrier does not offer non-stop service (i.e., there are layovers) between origin and 

destination, the traveler must use a U.S. flag carrier on every portion of the route where it 

provides service unless, when compared to a foreign carrier, such use would:

a. Increase the number of aircraft changes a traveler must make outside of the U.S. by 2 

or more; or

b. Extend travel time by at least 6 hours or more; or

c. Require a connecting time of 4 hours or more at an overseas interchange point. 

Open Skies Agreements

Open Skies agreements are bilateral air service agreements the U.S. Government negotiates with other 

countries to provide rights for airlines to offer international passenger and cargo services. The broad 

“Open Skies” term covers various types of aviation agreements, and many countries technically have an 

Open Skies agreement with the U.S. for a specific aviation-related service. That said, only a few 

countries have the type of agreement that includes provisions for federal government-funded 

passenger travel and the use of flag carriers. 

As of 2022, four countries/entities have the type of Open Skies agreement that covers LRC travel: 

• the European Union (E.U.) (plus Iceland and Norway per special amendments),

• Australia, 

• Japan, and

• Switzerland. 

Other Open Skies Agreements covering air transport and cargo movement do not apply to federally

funded travel. When other agreements become eligible, GSA will update its website here. 

Agreement with the European Union

The agreement between the United States and the European Union (27 countries, Iceland and Norway 

included through special amendments to the Open Skies agreement) is sweeping and lets passengers 

traveling on U.S. government funds use any E.U. carrier as long as the traveler stops in the E.U. along the 

way or as the destination. In return, it allows E.U.-funded travelers to use U.S. airlines on equal footing 

as E.U. airlines. 
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Appendix G – Fly America and Open Skies 37

Grantees may fly from any point in the U.S. to any point outside the U.S. on an E.U. airline whose 

country belongs to the agreement. Sample allowable itineraries:

• A point in the U.S. to a point in the E.U.: New York to Madrid.

• A point in the U.S. to a point in the E.U. to a further point in a foreign country (as long as there is 

a stop in an E.U. country): Washington to Paris to Istanbul. 

Grantees may also fly on an E.U. carrier between any two points outside the U.S. 

• Rome to Amsterdam.

• Frankfurt to Johannesburg, South Africa.

Agreements with Australia, Japan, and Switzerland

The agreements with Australia, Japan, and Switzerland are more limited and rely on specific city pair 

agreements between the two countries in question. City Pair exceptions are somewhat complex to 

check.

• If a City-Pair Program contract exists between the origin and the destination city, the grantee 

must take a U.S. airline (unless an above exception is authorized). Grantees need to check the

City-Pair Program website to verify that there is no City-Pair contract.

o Example: Washington, D.C. to Zurich has a City Pair Program contract, so the grantee 

must take a U.S. airline. 

• If no City Pair Program exists between the origin and the destination city, the grantee may take 

a U.S. carrier or an Australian, Japanese, or Swiss airline from the U.S. to the destination or from 

the destination to the U.S. 

o Boston to Osaka, Japan: No City-Pair Program exists, so the grantee can take an 

American or Japanese airline. 

o Boston to Tokyo, Japan: A City-Pair Program exists, so the grantee must take an 

American airline. 

o Boston to Tokyo, Japan, to Seoul, South Korea: Not allowable on a Japanese airline. 

Under the Agreements with Switzerland, Australia, and Japan, the traveler can only use 

a foreign airline from a point in the U.S. to a point in one of those three participating 

countries, or vice- versa. The traveler would have to fly on a U.S. airline from Boston to 

Korea unless the travel met another exception. 

• The grantee can also fly between any two points outside the United States on a Swiss, 

Australian, or Japanese airline. 

o Example: Australia to Indonesia.

Open Skies Frequently Asked Questions

Does the Fly America Act supersede Open Skies partnerships?
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Appendix G – Fly America and Open Skies 38

No. The four Open Skies agreements listed above allow U.S. government-funded travelers to use 

Open Skies-compliant carriers on equal footing as U.S. air carriers.

Are Turkish and British airlines included in the E.U. Open Skies agreement?

No. Only European Union member countries (plus Norway and Iceland) are covered under the Open 

Skies agreement with the E.U. Candidate countries and former E.U. members are not eligible to be 

included in the E.U. Open Skies agreement.

I have seen online that the U.S. has Open Skies agreements with countries not outlined on your list 

(e.g., South Korea as seen on this list). Are those countries’ flag carriers a possibility? 

No. The broad “Open Skies” term covers various types of aviation agreements between the U.S. and 

foreign countries. The link cited in the question shows many, if not all, of the various “Open Skies” 

agreements that exist between the U.S. and countries/entities around the world, but these may just 

allow the flag carriers of the U.S. and the partner to use each other’s airports, lease gate space, or 

facilitate the coordination of cargo planes.

While many countries/entities technically have an Open Skies agreement with the U.S., only four 

have the type of agreement that includes a provision for both countries to allow governmentfunded travelers from the partner to use government funds to travel on the partner country’s air 

carriers.

In short, the U.S. and South Korea have a broad Open Skies agreement that allows U.S. carriers to fly 

into South Korea and vice-versa, but do NOT have the type of Open Skies agreement that allows U.S. 

government-funded travelers to use a South Korean airline on the same footing as a U.S. airline.

Verifying Compliance in IRIS

When submitting a Travel Approval Request (TAR), grantees must certify that their proposed 

international itinerary complies with the Fly America Act and/or Open Skies agreement. If the travel is 

eligible for an exception or allowable under an Open Skies partnership, the grantee should explain why

in the “comments” section. For more information on Travel Approval Requests, see page 16.
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Appendix H – Subaward Resources 39

Appendix H – Subaward Resources

IFLE defers to each institution’s office of sponsored projects to determine the required documentation 

and paperwork for subawards made on a Title VI grant. Please review the Department’s webpage 

addressing subaward management for more information.

Each subaward must have a formal written agreement for meeting the administrative, financial, and 

reporting requirements of a grant. IFLE holds grantees accountable for their subawardees' research, 

spending, and reporting actions, which must conform to all terms and conditions of the grant 

award. The guidance below is intended to help draft such an agreement and assist the primary 

institution in monitoring of the implementation of the subaward.

Note: The following are sections of the Uniform Guidance which relate to subaward management. It is 

not the Uniform Guidance in its entirety, nor is it a complete list of sections related to subaward 

management. 

Key Sections of Uniform Guidance Related to Subawards 

2 CFR § Part 200 Subpart A

§200.74 PASS-THROUGH ENTITY. 

Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to 

carry out part of a Federal program.

§200.92 SUBAWARD. 

 Subaward means 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 of legal agreement, including an agreement that the passthrough entity considers a contract.

§200.93 SUBRECIPIENT. 

Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to 

carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. 

A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.

2 CFR § Part 200 Subpart C

§200.205 FEDERAL AWARDING AGENCY REVIEW OF RISK POSED BY APPLICANTS. 

(a) Prior to making a Federal award, the Federal awarding agency is required by 31 U.S.C. 3321 and 41 

U.S.C. 2313 note to review information available through any OMB-designated repositories of 

governmentwide eligibility qualification or financial integrity information, such as SAM Exclusions 
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Appendix H – Subaward Resources 40

and “Do Not Pay”. See also suspension and debarment requirements at 2 CFR § part 180 as well as 

individual Federal agency suspension and debarment regulations in title 2 of the Code of Federal 

Regulations.

(b) In addition, for competitive grants or cooperative agreements, the Federal awarding agency must 

have in place a framework for evaluating the risks posed by applicants before they receive Federal 

awards. This evaluation may incorporate results of the evaluation of the applicant's eligibility or the 

quality of its application. If the Federal awarding agency determines that a Federal award will be 

made, special conditions that correspond to the degree of risk assessed may be applied to the 

Federal award. Criteria to be evaluated must be described in the announcement of funding 

opportunity described in §200.203 Notices of funding opportunities.

(c) In evaluating risks posed by applicants, the Federal awarding agency may use a risk-based approach 

and may consider any items such as the following:

(1) Financial stability;

(2) Quality of management systems and ability to meet the management standards prescribed 

in this part;

(3) History of performance. The applicant's record in managing Federal awards, if it is a prior 

recipient of Federal awards, including timeliness of compliance with applicable reporting 

requirements, conformance to the terms and conditions of previous Federal awards, and if 

applicable, the extent to which any previously awarded amounts will be expended prior to 

future awards;

(4) Reports and findings from audits performed under Subpart F—Audit Requirements of this 

part or the reports and findings of any other available audits; and

(5) The applicant's ability to effectively implement statutory, regulatory, or other requirements 

imposed on non-Federal entities.

(d) In addition to this review, the Federal awarding agency must comply with the guidelines on 

governmentwide suspension and debarment in 2 CFR § part 180, and must require non-Federal 

entities to comply with these provisions. These provisions restrict Federal awards, subawards and 

contracts with certain parties that are debarred, suspended or otherwise excluded from or 

ineligible for participation in Federal programs or activities.

§200.207 SPECIFIC CONDITIONS. 

(a) The Federal awarding agency or pass-through entity may impose additional specific award 

conditions as needed, in accordance with paragraphs (b) and (c) of this section, under the following 

circumstances:

(1) Based on the criteria set forth in §200.205 Federal awarding agency review of risk posed by 

applicants;

(2) When an applicant or recipient has a history of failure to comply with the general or 

specific terms and conditions of a Federal award;

(3) When an applicant or recipient fails to meet expected performance goals as described in 

§200.210 Information contained in a Federal award; or

(4) When an applicant or recipient is not otherwise responsible.

(b) These additional Federal award conditions may include items such as the following:

(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;
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Appendix H – Subaward Resources 41

(4) Requiring additional project monitoring;

(5) Requiring the non-Federal entity to obtain technical or management assistance; or

(6) Establishing additional prior approvals. 

(c) The Federal awarding agency or pass-through entity must notify the applicant or non-Federal entity 

as to:

(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 requirement, if applicable;

(4) The time allowed for completing the actions if applicable, and

(5) The method for requesting reconsideration of the additional requirements imposed.

(6) Any specific conditions must be promptly removed once the conditions that prompted 

them have been corrected.

2 CFR § Part 200 Subpart D

SUBRECIPIENT MONITORING AND MANAGEMENT

§200.330 SUBRECIPIENT AND CONTRACTOR DETERMINATIONS. 

The non-Federal entity may concurrently receive Federal awards as a recipient, a subrecipient, and 

a contractor, depending on the substance of its agreements with Federal awarding agencies and passthrough entities. Therefore, a pass-through entity must make case-by-case determinations whether each 

agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in 

the role of a subrecipient or a contractor. The Federal awarding agency may supply and require recipients to 

comply with additional guidance to support these determinations provided such guidance does not conflict 

with this section.

(a) Subrecipients. A subaward is for the purpose of carrying out a portion of a Federal award and 

creates a Federal assistance relationship with the subrecipient. See §200.92 Subaward. 

Characteristics which support the classification of the non-Federal entity as a subrecipient include 

when the non-Federal entity:

(1) Determines who is eligible to receive what Federal assistance;

(2) Has its performance measured in relation to whether objectives of a Federal program were 

met;

(3) Has responsibility for programmatic decision making;

(4) Is responsible for adherence to applicable Federal program requirements specified in the 

Federal award; and

(5) In accordance with its agreement, uses the Federal funds to carry out a program for a 

public purpose specified in authorizing statute, as opposed to providing goods or services 

for the benefit of the pass-through entity.

(b) Contractors. A contract is for the purpose of obtaining goods and services for the non-Federal 

entity's own use and creates a procurement relationship with the contractor. See §200.22 Contract. 

Characteristics indicative of a procurement relationship between the non-Federal entity and a 

contractor are when the non-Federal entity receiving the Federal funds:

(1) Provides the goods and services within normal business operations;

(2) Provides similar goods or services to many different purchasers;

(3) Normally operates in a competitive environment;

(4) Provides goods or services that are ancillary to the operation of the Federal program; and
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Appendix H – Subaward Resources 42

(5) Is not subject to compliance requirements of the Federal program as a result of the 

agreement, though similar requirements may apply for other reasons.

(c) Use of judgment in making determination. In determining whether an agreement between a passthrough entity and another non-Federal entity casts the latter as a subrecipient or a contractor, the 

substance of the relationship is more important than the form of the agreement. All of the 

characteristics listed above may not be present in all cases, and the pass-through entity must use 

judgment in classifying each agreement as a subaward or a procurement contract.

§200.331 REQUIREMENTS FOR PASS-THROUGH ENTITIES. 

All pass-through entities must:

(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the 

following information at the time of the subaward and if any of these data elements change, 

include the changes in subsequent subaward modification. When some of this information is not 

available, the pass-through entity must provide the best information available to describe the 

Federal award and subaward. Required information includes:

(1) Federal Award Identification.

(i) Subrecipient name (which must match the name associated with its unique entity; 

(ii) Subrecipient's unique entity identifier;

(iii) Federal Award Identification Number (FAIN);

(iv) Federal Award Date (see §200.39 Federal award date);

(v) Subaward Period of Performance Start and End Date;

(vi) Amount of Federal Funds Obligated by this action;

(vii) Total Amount of Federal Funds Obligated to the subrecipient;

(viii) Total Amount of the Federal Award;

(ix) Federal award project description, as required to be responsive to the Federal 

Funding Accountability and Transparency Act (FFATA);

(x) Name of Federal awarding agency, pass-through entity, and contact information 

for awarding official,

(xi) CFDA Number and Name; the pass-through entity must identify the dollar amount 

made available under each Federal award and the CFDA number at time of 

disbursement;

(xii) Identification of whether the award is R&D; and

(xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged 

per §200.414 Indirect (F&A) costs).

(2) All requirements imposed by the pass-through entity on the subrecipient so that the 

Federal award is used in accordance with Federal statutes, regulations and the terms and 

conditions of the Federal award.

(3) Any additional requirements that the pass-through entity imposes on the subrecipient in 

order for the pass-through entity to meet its own responsibility to the Federal awarding 

agency including identification of any required financial and performance reports;

(4) An approved federally recognized indirect cost rate negotiated between the subrecipient 

and the Federal Government or, if no such rate exists, either a rate negotiated between the 

pass-through entity and the subrecipient (in compliance with this part), or a de minimis 

indirect cost rate as defined in §200.414 Indirect (F&A) costs, paragraph (f) of this part.
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Appendix H – Subaward Resources 43

(5) A requirement that the subrecipient permit the pass-through entity and auditors to have 

access to the subrecipient's records and financial statements as necessary for the passthrough entity to meet the requirements of this part; and

(6) Appropriate terms and conditions concerning closeout of the subaward.

(b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the 

terms and conditions of the subaward for purposes of determining the appropriate subrecipient 

monitoring described in paragraphs (d) and (e) of this section, which may include consideration of 

such factors as:

(1) The subrecipient's prior experience with the same or similar subawards;

(2) The results of previous audits including whether or not the subrecipient receives a Single 

Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to 

which the same or similar subaward has been audited as a major program;

(3) Whether the subrecipient has new personnel or new or substantially changed systems; and

(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also 

receives Federal awards directly from a Federal awarding agency).

(c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in 

§200.207 Specific conditions.

(d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for 

authorized purposes, in compliance with Federal statutes, regulations, and the terms and 

conditions of the subaward; and that subaward performance goals are achieved. Pass-through 

entity monitoring of the subrecipient must include:

(1) Reviewing financial and performance reports required by the pass-through entity.

(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all 

deficiencies pertaining to the Federal award provided to the subrecipient from the passthrough entity detected through audits, on-site reviews, and other means.

(3) Issuing a management decision for audit findings pertaining to the Federal award provided 

to the subrecipient from the pass-through entity as required by §200.521 Management 

decision.

(e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as 

described in paragraph (b) of this section), the following monitoring tools may be useful for the 

pass-through entity to ensure proper accountability and compliance with program requirements 

and achievement of performance goals:

(1) Providing subrecipients with training and technical assistance on program-related matters; 

and

(2) Performing on-site reviews of the subrecipient's program operations;

(3) Arranging for agreed-upon-procedures engagements as described in §200.425 Audit 

services.

(f) Verify that every subrecipient is audited as required by Subpart F—Audit Requirements of this part 

when it is expected that the subrecipient's Federal awards expended during the respective fiscal 

year equaled or exceeded the threshold set forth in §200.501 Audit requirements.
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Appendix H – Subaward Resources 44

(g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring 

indicate conditions that necessitate adjustments to the pass-through entity's own records.

(h) Consider taking enforcement action against noncompliant subrecipients as described in §200.338 

Remedies for noncompliance of this part and in program regulations.

§200.332 FIXED AMOUNT SUBAWARDS. 

With prior written approval from the Federal awarding agency, a pass-through entity may provide 

subawards based on fixed amounts up to the Simplified Acquisition Threshold, provided that the subawards 

meet the requirements for fixed amount awards in §200.201 Use of grant agreements (including fixed 

amount awards), cooperative agreements, and contracts.

§200.338 REMEDIES FOR NONCOMPLIANCE. 

If a non-Federal entity fails to comply with Federal statutes, regulations or the terms and 

conditions of a Federal award, the Federal awarding agency or pass-through entity may impose 

additional conditions, as described in §200.207 Specific conditions. If the Federal awarding agency or 

pass-through entity determines that noncompliance cannot be remedied by imposing additional 

conditions, the Federal awarding agency or pass-through entity may take one or more of the following

actions, as appropriate in the circumstances:

(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal 

entity or more severe enforcement action by the Federal awarding agency or pass-through 

entity.

(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the 

cost of the activity or action not in compliance.

(c) Wholly or partly suspend or terminate the Federal award.

(d) Initiate suspension or debarment proceedings as authorized under 2 CFR § part 180 and Federal 

awarding agency regulations (or in the case of a pass-through entity, recommend such a 

proceeding be initiated by a Federal awarding agency).

(e) Withhold further Federal awards for the project or program.

(f) Take other remedies that may be legally available.

2 CFR § Part 200 Subpart E

200.425 AUDIT SERVICES.

(a) A reasonably proportionate share of the costs of audits required by, and performed in 

accordance with, the Single Audit Act Amendments of 1996 (31 U.S.C. 7501-7507), as 

implemented by requirements of this part, are allowable. However, the following audit costs are 

unallowable: 

(1) Any costs when audits required by the Single Audit Act and Subpart F—Audit 

Requirements of this part have not been conducted or have been conducted but not in 

accordance therewith; and

(2) Any costs of auditing a non-Federal entity that is exempted from having an audit 

conducted under the Single Audit Act and Subpart F—Audit Requirements of this part 
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Appendix H – Subaward Resources 45

because its expenditures under Federal awards are less than $750,000 during the nonFederal entity's fiscal year.

(b) The costs of a financial statement audit of a non-Federal entity that does not currently have a 

Federal award may be included in the indirect cost pool for a cost allocation plan or indirect cost 

proposal.

(c) Pass-through entities may charge Federal awards for the cost of agreed-upon-procedures 

engagements to monitor subrecipients (in accordance with Subpart D—Post Federal Award 

Requirements of this part, §200.330 Subrecipient and contractor determinations through 

200.332 Fixed Amount Subawards) who are exempted from the requirements of the Single 

Audit Act and Subpart F—Audit Requirements of this part. This cost is allowable only if the 

agreed-upon-procedures engagements are:

(1) Conducted in accordance with GAGAS attestation standards;

(2) Paid for and arranged by the pass-through entity; and

(3) Limited in scope to one or more of the following types of compliance requirements: 

activities allowed or unallowed; allowable costs/cost principles; eligibility; and reporting.

2 CFR § Part 200 Subpart F

§200.501 AUDIT REQUIREMENTS. 

(a) Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity's 

fiscal year in Federal awards must have a single or program-specific audit conducted for that year in 

accordance with the provisions of this part.

(b) Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity's 

fiscal year in Federal awards must have a single audit conducted in accordance with §200.514 

Scope of audit except when it elects to have a program-specific audit conducted in accordance with 

paragraph (c) of this section.

(c) Program-specific audit election. When an auditee expends Federal awards under only one Federal 

program (excluding R&D) and the Federal program's statutes, regulations, or the terms and 

conditions of the Federal award do not require a financial statement audit of the auditee, the 

auditee may elect to have a program-specific audit conducted in accordance with §200.507 

Program-specific audits. A program-specific audit may not be elected for R&D unless all of the 

Federal awards expended were received from the same Federal agency, or the same Federal 

agency and the same pass-through entity, and that Federal agency, or pass-through entity in the 

case of a subrecipient, approves in advance a program-specific audit.

(d) Exemption when Federal awards expended are less than $750,000. A non-Federal entity that 

expends less than $750,000 during the non-Federal entity's fiscal year in Federal awards is exempt 

from Federal audit requirements for that year, except as noted in §200.503 Relation to other audit 

requirements, but records must be available for review or audit by appropriate officials of the 

Federal agency, pass-through entity, and Government Accountability Office (GAO).

(e) Federally Funded Research and Development Centers (FFRDC). Management of an auditee that 

owns or operates a FFRDC may elect to treat the FFRDC as a separate entity for purposes of this 

part.
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Appendix H – Subaward Resources 46

(f) Subrecipients and Contractors. An auditee may simultaneously be a recipient, a subrecipient, and a 

contractor. Federal awards expended as a recipient or a subrecipient are subject to audit under this 

part. The payments received for goods or services provided as a contractor are not Federal awards. 

Section §200.330 Subrecipient and contractor determinations sets forth the considerations in 

determining whether payments constitute a Federal award or a payment for goods or services 

provided as a contractor.

(g) Compliance responsibility for contractors. In most cases, the auditee's compliance responsibility for 

contractors is only to ensure that the procurement, receipt, and payment for goods and services 

comply with Federal statutes, regulations, and the terms and conditions of Federal awards. Federal 

award compliance requirements normally do not pass through to contractors. However, the 

auditee is responsible for ensuring compliance for procurement transactions which are structured 

such that the contractor is responsible for program compliance or the contractor's records must be 

reviewed to determine program compliance. Also, when these procurement transactions relate to a 

major program, the scope of the audit must include determining whether these transactions are in 

compliance with Federal statutes, regulations, and the terms and conditions of Federal awards.

(h) For-profit subrecipient. Since this part does not apply to for-profit subrecipients, the pass-through 

entity is responsible for establishing requirements, as necessary, to ensure compliance by for-profit 

subrecipients. The agreement with the for-profit subrecipient must describe applicable compliance 

requirements and the for-profit subrecipient's compliance responsibility. Methods to ensure 

compliance for Federal awards made to for-profit subrecipients may include pre-award audits, 

monitoring during the agreement, and post-award audits. See also §200.331 Requirements for 

pass-through entities.
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Appendix I – The Site Visit 47

Appendix I – The Site Visit 

During the grant performance period, the U.S. Department of Education program officer may conduct an 

on-site or virtual site visit of the grantee’s project. The program officer will provide the grantee a report 

after the site visit has concluded.

Potential Purposes for Conducting a Visit

• Assess internal controls

• Ensure compliance with approved plan

• Identify project strengths and areas for improvement

• Observe and document promising practices

• Provide technical assistance

• Respond to complaints/high risk evidence

Pre-visit Preparation

• Program officer notifies grantee of proposed dates for the site visit 

• Once the dates are established, the program officer sends a letter to the grantee that includes 

the following:

o Confirmed dates

o Purpose of the visit

o ED staff conducting the visit

o Requested meetings, participants/interviewees

o Requested financial documents/documentation and date to receive

o Date to receive the first draft of the site visit agenda

• The grantee(s) may be asked to prepare a detailed agenda for the site visit.

Requested documents may include, but are not limited to, the following:

• Relevant organizational charts

• Policies and procedures for program management and fiscal operations

• Chart of accounts

• Key personnel lists and their time and effort forms

• Documentation for federal drawdowns to disbursements for the specified grant project

• Payroll documentation for the last 12 months

• Financial transactions for the last 12 months

• List of contracts supported with grant funds

• Project-related travel documentation

• A-133 audit documents (letter, summary sheet of findings and questioned costs, if applicable)
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Appendix J – Open Licensing and Citing Support 48

Appendix J – Open Licensing and Citing Support 

As an institution receiving funding from the International and Foreign Language Education (IFLE) office 

of the U.S. Department of Education, it is beneficial both to you, as a grantee, and to the Federal 

Government, to publicize your project’s activities and results. As an IFLE grantee, you are required to 

properly cite the LRC program in all related publications, websites, newsletters, and press releases. Also, 

please provide a link to the IFLE website (www.ed.gov/ope/iegps) somewhere on your project website. 

Open Licensing Requirements for Grant Deliverables

Unless an exception applies, you are required to openly license to the public grant deliverables created 

in whole, or in part, with Department grant funds. When the deliverable consists of modifications to 

pre-existing works, the license extends only to those modifications that can be separately identified and 

only to the extent that open licensing is permitted under the terms of any licenses or other legal 

restrictions on the use of pre-existing works. 

Additionally, a grantee or subgrantee that is awarded competitive grant funds must have a plan to 

disseminate these public grant deliverables. This dissemination plan can be developed and submitted 

after your application has been reviewed and selected for funding. 

• Grantees must openly license to the public any grant deliverable that is created wholly or in part 

with Department competitive grant funds.

• Grantees must grant to the public a worldwide, non-exclusive, royalty-free, perpetual, and 

irrevocable license to access, reproduce, prepare derivative works, publicly perform, publicly 

display, and distribute the copyrightable work provided that attribution is given to the copyright 

holder.

• The open license also must contain a symbol or device that readily communicates to users the 

permissions granted concerning the use of the copyrightable work; machine-readable code for 

digital resources; readily accessed legal terms; and the statement of attribution.

• Grantees may select any open licenses that comply with the requirements of this section, 

including, at the grantee’s discretion, a license that limits use to noncommercial purposes.

• A grantee that is awarded competitive grant funds must have a plan to disseminate the openly 

licensed copyrightable works created with grant funds.

• The rule does not apply to:

o funding for general operating expenses;

o support to individuals (e.g., scholarships, fellowships);

o grant deliverables that are jointly funded by the Department and another Federal 

agency if the other Federal agency does not require open licensing;

o copyrightable works not created with Department grant funds;

o peer-reviewed scholarly publications funded by the Department;

o grantees under the Ready To Learn Television Program; or

o a grantee that has received an exception from the Secretary of Education.
LRC Program Administration Manual

FY 2022-2025 

Appendix J – Open Licensing and Citing Support 49

For additional information on the open licensing requirements, please refer to 2 CFR § 3474.20 and visit 

the website for the Department's Office of Educational Technology. 

Format for Acknowledging the Use of Federal Funds in Publications 

and Other Project Materials

You must cite International and Foreign Language Education (IFLE) as your funding source in all projectrelated publications, websites, and press releases. The term “project materials” means a copyrightable 

work developed with funds from a grant issued by the Department. (34 CFR § 75.622)

The following is the required citation (34 CFR § 75.620) for any digital or print publication that contains IFLE 

project materials:

“The contents of this [insert type of publication, such as book report, film] were developed under a 

grant from the U.S. 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.”
LRC Program Administration Manual

FY 2022-2025 

Appendix K – Engage with IFLE Flyer 50

Appendix K – Engage with IFLE Flyer

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