Appalachian Regional Commission

GRANT ADMINISTRATION MANUAL 

For ARC Non-Construction Grants

February 2020

1666 Connecticut Ave NW, Suite 700

Washington DC 20009-1068
Appalachian Regional Commission, February 2020 Page 2

TABLE OF CONTENTS 

INTRODUCTION 3

PROJECT MANAGEMENT 3

REPORTS 5

FORMAT AND CONTENTS OF PROJECT NARRATIVE REPORTS 7

FINANCIAL REPORTS AND PAYMENT REQUESTS 9

CHANGES TO A PROJECT 10

RECORD KEEPING AND AUDITS 12

AFTER PROJECT COMPLETION 14
Appalachian Regional Commission, February 2020 Page 3

Introduction 

This manual provides guidance on post-award administration of ARC non-construction projects 

from approval to closeout.

If you have questions about any aspect of your ARC grant, please contact the State Program 

Manager or the ARC project coordinator listed on the first page of your grant agreement. The 

mailing address is:

Appalachian Regional Commission

1666 Connecticut Avenue NW, Suite 700

Washington, DC 20009-1068

Fax: (202) 884-7682

Project Management 

What to Do First

Before starting an ARC project, read your ARC Grant 

Agreement. The grant agreement is like a contract and 

will serve as a guide throughout the grant performance 

period. You are responsible for complying with all terms 

of the Grant Agreement.

Log in to ARCnet, ARC’s grants management system, to 

access your electronic project record. If you have not 

established an account, click on the link for new users on 

the main page and follow the instructions to create a 

new account. You are responsible for keeping the contact 

information up to date in ARCnet for your project.

NOTE: Your email must be listed in ARCnet in order to log in. You are only able to see projects that 

include you with your email address under “contacts”. If you are not able to log in or cannot find a 

project, the primary account holder(s) in your organization must add you as a contact in ARCnet.

ARC Grant Agreements are stored in the electronic record of your project in ARCnet, and can be 

found in the “Documentation” section under “Files.” The ARC Grant Agreement also identifies your 

ARC project coordinator and his/her contact information.

The project’s start and end dates (the “project period” or “period of performance”) are listed on the 

“Report” tab. Do not begin project activities before the project’s start date nor continue them 

beyond the end date as only activities conducted during the period of performance are eligible for 

reimbursements or are able to count as part of the matching contribution.

Log on to ARCnet at 

https://arcnet.arc.gov to:

Review ARC Grant Agreement

Track payment & 

amendment requests

View projectedperformance 

measures

Add/Change project contacts

Check reporting deadlines

Identify ARC project coordinator
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The report tab also contains the reporting period and due date for your progress and final reports. 

Monitor these dates to be sure that you meet ARC’s reporting requirements. Review the projected 

performance measures for your project, also found in the ARCnet record in the “Performance” 

section. You are responsible for tracking these measures and reporting your progress in interim 

and final reports to ARC.

For assistance logging in or using ARCnet, email itsupport@arc.gov.

Starting the Project

You should begin work on your ARC-funded project as soon as the grant agreement’s period of 

performance begins. Unless explicitly stated in your ARC Grant Agreement or ARC Approval Memo, 

you do not have to contact ARC before you begin. ARC and state contacts are available to answer 

questions and provide guidance as needed.

Procurement

If your project involves procurement, e.g., for a service or a product, your ARC project coordinator 

may ask to review your written procurement procedures before the project starts. Regardless of 

whether you are asked to share these procedures with ARC, each procurement must comply with 

federal procurement standards.

State agencies follow their own procurement policies and procedures. All other grantees must 

competitively bid procurements according to the procurement standards in the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, found 

at 2 C.F.R. 200.317-326. See Part II, Articles 5 and 6 of your ARC Grant Agreement for more details 

about contracting procedures.

Contracting or Subawarding for Services

Prior ARC approval is required before subawarding, transferring or contracting out work under 

your ARC grant, unless identified in the original, approved work plan, or any approved revision.

The decision as to whether to award a subgrant or to make a procurement must be made on a 

case-by-case basis. It is important to get this decision right because legal obligations of a 

subgrantee differ from those of a contractor. Federal regulations should be consulted at 2 CFR 

200.330, Subrecipient and contractor determinations.

Suspension and Debarment

All recipients and subrecipients of ARC funds are subject to suspension and debarment regulations 

at 2 CFR Part 180, which restrict awards, subawards, and contracts with parties that are debarred, 

suspended, or otherwise excluded from participation in federal assistance programs or activities.

All recipients and subrecipients of ARC funds must be registered on GSA’s System for Award 

Management (SAM), which contains the electronic roster of suspended and debarred entities that 

are ineligible from receiving federal assistance and benefits.
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Grantees are responsible for ensuring that subgrantees and/or contractors have not been 

suspended, debarred, or disqualified by checking https://www.sam.gov/SAM/ for SAM Exclusions. 

Grantees must check this information not only before a subaward, contract, or loan is made, but 

also during the performance period.

Reports 

To view the requirements for reporting, refer to Article 4 Reports, found in Part II of the ARC Grant 

Agreement.

Reporting Intervals

The reporting period begins with the start date of the grant agreement. ARC requires interim 

progress reports every 120 days or every four months and a final report at the end of your project’s 

period of performance. Reports are due no later than 30 days after the close of a reporting period.

If program activities did not start within this period, or if the project is delayed any time during the 

reporting period, narrative and financial progress reports are still required, explaining the reasons 

for the delay and how any problems are being resolved.

Due Date for Final Reports

The final narrative report and all financial documents are due within 30 days of the end of the 

project. After your ARC project coordinator accepts your report, he/she will prepare a closeout 

report which becomes the basis for closing the grant agreement. If a delay in submitting the final 

narrative report is expected, the grantee should notify the ARC project coordinator.

Required Content for All Reports

Both interim and final reports must include:

1. ARC-PPR Performance Progress Report (ARC cover page). This form is available on ARC’s 

web site. Box 8 of the PPR should be marked as ‘interim’ or ‘final’ as applicable.

2. The Performance Narrative - The performance narrative is listed in section 10 of the ARCPPR, but should be attached as a separate document.

3. Standard Form 270–Request for Advance or Reimbursement; and

4. An ARC Reimbursement and Payment Advance Request Worksheet that summarizes 

actual expenditures by approved budget line items.

If requesting an advance payment, a brief justification is also required. Contact your ARC project 

coordinator for more details. Financial documentation is required even if no reimbursement is 

being requested for the reporting period.
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 Performance Measures

Performance measures are stored on ARCnet on the “Performance” tab of your electronic project 

record and also on the approval memo found on the “Documentation” tab. ARC records projected 

outcomes and outputs upon approval of a project. Actual outcomes and outputs must be reported 

when a project is completed.

For a list and definitions of the output and outcome performance measures that may be used for 

ARC projects, please review the Guide to ARC Project Performance Measures.

Required Content for Final Narrative Report Only

The final report is your opportunity to share the significant features of your project and present 

information about the results your project achieved. The document should be written as if the 

reader has no previous knowledge of your project’s activities. The report should cover the entire 

period of performance. It must review and highlight all activities that occurred during the 

implementation of the project, including an assessment of all performance measures that were 

proposed in the ARC project application. See below for more information regarding required report 

contents.

Submitting Reports

Reports should be completed in the appropriate electronic format and emailed to the project 

coordinator as file attachments to the body of an email message. Reports must include the 

complete grant number (including all hyphens) in the subject line of your email message and on 

all other correspondence. Note that grant numbers have letters, numbers, hyphens (-), and no 

spaces, e.g. AL-12345-15.

Reports should be emailed to your ARC project coordinator. His/her email address is listed on your 

ARC Grant Agreement. The State Program Manager listed on your Grant Agreement should be 

copied on the email. Other state ARC contacts, as specified by your state ARC program office, 

should be copied as well. Other individuals from the grantee’s organization may also be included in 

the email if desired by the grantee’s organization. Grantees that do not have the technological 

capability to submit electronic files, or have report content that cannot be submitted electronically, 

should make alternate arrangements with their ARC project coordinator.

If you have questions regarding the information needed for reports, call or email the ARC project 

coordinator identified on page one of the ARC Grant Agreement. Include the complete grant 

number (including all hyphens) in the subject line of your email message and on all other 

correspondence, e.g. AL-12345-15, exactly as it appears in your ARC Grant Agreement.

Appending Narrative Reports to the Arcnet Electronic Record

The ARC project coordinator will upload your report(s) to ARCnet, ARC’s grants management 

system, after reports have been reviewed and accept
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Summary of ARC Reports

Interim Final

How often?

Every 120 days or every 4 months 

beginning with the project start date. Due 

within 30 days of end of the reporting 

period.

Due within 30 days of end 

of the grant performance 

period.

Activities 

covered

Only those occurring in that reporting 

period.

Schedule of activities for the next reporting 

period.

Cumulative for the entire 

performance period of the 

grant.

Financial report 

required?

Yes

Forms & 

content 

required

ARC-PPR, marked as interim 

Interim Narrative Report 

SF270, marked as partial ARC 

Backup Worksheet(s),

Reimbursement and/or Advance Payment 

Request

Justification for advance if applicable

ARC-PPR, marked as final 

Final Narrative Report 

SF270, marked as final 

ARC Backup Worksheet, 

Reimbursement Request 

only

Narrative 

format

Use ARC format provided in this manual

Email ARC Project Coordinator w/ CC to the State Program Manager

Format and Contents of Project Narrative Reports 

 Cover Page

The ARC-PPR form serves as the report’s cover page and must be signed by an authorized 

individual. The ARC-PPR should accompany each interim progress report and the final report. 

Unless instructed otherwise by your ARC project coordinator, attach a narrative (section 10 on the 

ARC-PPR) covering the elements listed below, as a separate document.

Background

Provide a short statement regarding the need for this project. What problems did you hope to 

solve when you applied for ARC funding?
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Recent/Upcoming Activities

Describe in detail what happened during this reporting period and explain how you implemented 

the approved scope of work. If there have been significant changes to your program during the 

course of the project, or if the project was implemented differently than described in your original 

proposal, please describe those changes here. If you retained a consultant, list their credentials and 

describe what they were paid to do.

Progress Made Toward Project Outcomes

Provide any statistical information that helps document the outputs and outcomes of your project 

to date. Data will vary according to the type of activities you completed. Although it may be 

difficult to document outcomes (results) at this time, grantees should report progress made todate. If outputs and/or outcomes will not be attained until after the end of the grant period, predict 

the likelihood of meeting those original targets—and give a date. You are responsible for accurately 

tracking and documenting all listed outputs and outcomes from the Approval Memo and the 

Performance tab in ARCnet.

Sample Summary Table of Performance 

Measures

Projected Outputs Actual Outputs for the Reporting Period

Projected Outcomes Actual Outcomes for the Reporting Period

For the final report, write an assessment of how your project has impacted the problems you were 

trying to solve. Were there unexpected benefits? Shortfalls? Also, provide a summary table of the 

outputs and the outcomes achieved to-date for the entire project performance period as 

applicable.

Problems Encountered

Describe any and all major issues that arose during the implementation of the project. What would 

you do differently if you were starting this project again? Knowing the types of difficulties you 

encountered and how you resolved them will guide us in offering technical assistance to future 

grant applicants. Address each issue separately in its own section, and describe whether and how 

the issues were resolved. Also, briefly discuss the implications of any unresolved issues or concerns.

Outlook for Program Continuation and Sustainability

Describe how the project activities will be sustained without the grant funding. Did the project 

generate income? Will the program continue with other funding, and if so, what other sources of 

funds have been identified? If the program is to be discontinued, has it served its purpose, or is 

there still a need to solve the problems you were addressing? What additional steps are being 

taken to obtain other resources needed to continue the project?

Conclusions and Recommendations (For Final Report)

Summarize your entire project and the lessons learned during its implementation. Include a review 

of your successes and suggest ways that your experience may be helpful to others.
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Attachments

Attach or include material that helps to describe your project and documents your success, such as 

photographs, news clippings, maps, links to videos, and/or website addresses. Also, please attach 

copies of any written evaluations that may have been completed for your project.

NOTE: You should have written permission or releases signed by the individuals and/or their 

guardians, to use photos of any recognizable individuals before sending them to ARC. Do not send 

the photo releases but retain them with your project files

Do not send personally identifiable information, as defined in 2 CFR 200.79, e.g. social security 

numbers, birthdates. Grant files are subject to public inspection.

Financial Reports and Payment 

ARC Reimbursement Process

ARC makes electronic payments to grantees using the Automated Clearinghouse (ACH) payment 

system. No payments will be made without a completed ACH enrollment form (SF 3881) on file. The 

SF3881 enrollment form with instructions was included with the ARC Grant Agreement that was 

electronically sent to the individual named as the project executive, and is available on ARC’s 

website. If your organization is registered with the System for Award Management (SAM), 

information about your financial institution submitted to ARC on the SF3881 must be consistent 

with information found in SAM or payment will not be made.

Financial forms are reviewed to confirm that expenditures are consistent with the approved 

budget and reflect the project’s progress described in the narrative report.

Payments may be tracked by logging in to ARCnet and viewing the electronic record for your 

project. Select the “Financial” tab, and then select “Payment” for a record of all payments.

Requesting a Reimbursement

Reimbursement requests should be signed, scanned and emailed to ARC. Payment requests must 

include the following documents:

1. ARC-PPR Performance Progress Report (ARC cover page). This form is available on ARC’s 

web site. Box 8 of the PPR should be marked as ‘interim’ or ‘final’ as applicable.

2. The Performance Narrative - The performance narrative is listed in section 10 of the ARCPPR, but should be attached as a separate document.

3. Standard Form 270 - Request for Advance or Reimbursement; and

4. An ARC Reimbursement and Payment Advance Request Worksheet that summarizes 

actual expenditures by approved budget line items.

Payment forms were included with your ARC Grant Agreement and are available on ARC’s website. 

Both ARC and matching funds must be identified in the backup worksheet that accompanies all 

payment requests.

The ARC Grant Agreement, Part II, Article 11, outlines the conditions which must be met for a 

grantee to receive reimbursement for incurred expenses. Unless there are unforeseen or 

outstanding issues, payments will be made within 30 days after a grantee submits both a detailed 

progress narrative report and corresponding accurate and completed financial documentation. 

Payments will not be authorized until the ARC project coordinator has received and accepted both 

components.
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ARC routinely withholds the final 10 percent of the grant amount until the final reports are 

accepted and the project is closed.

Requesting an Advance Payment

ARC will advance funds, but usually for no more than one reporting period and never for the final 

payment at time of closeout. The advance payment request should include:

A statement explaining why an advance is necessary;

Standard Form 270 - Request for Advance or Reimbursement

An ARC Reimbursement and Payment Advance Request Worksheet showing estimated 

expenditures for each approved line item in the official budget for the forecasted period.

A reimbursement and advance may be included in a single payment request accompanied by 

separate worksheets for the reimbursement and for the advance and one SF270. The advance 

worksheet is included as the second tab of the Excel file “Reimbursement and Payment Advance 

Request Worksheet.”

Requesting a Final Payment

The final payment due to the grantee is contingent upon submission to ARC, and ARC’s approval of 

the final narrative report and final financial report. Final payments are processed when the project 

closeout is complete and may take longer than interim payment requests.

Final written and financial reports should reflect activities and costs for the entire grant

performance period. The final reports must include the source(s) and amount(s) of all matching 

funds. The final Reimbursement Request Worksheet should also detail how all matching funds 

were used.

Changes to a Project 

Making Changes to Grantee’s Financial Institution

Complete a new ACH enrollment form if your financial institution changes during the period of 

performance for your ARC Grant Agreement. Include a note indicating that it is revised and submit 

the new form by mail or by fax to the ARC Finance Office, 1666 Connecticut Ave. NW, Suite 700, 

Washington, DC 20009-1068; Fax number (202) 884-7691. Be sure to include your full ARC project 

number on the form.

Changing the Period of Performance of an ARC Grant Agreement

If a project cannot be completed within the approved period of performance, an extension request 

may be made by email to your ARC project coordinator and the State Program Manager. The 

request must be received and approved prior to the project end date listed in the grant 

agreement. The request must include the reason for the extension and the proposed revision to 

the end date. Approval of a project extension is contingent on the state’s concurrence.
Appalachian Regional Commission, February 2020 Page 11

Changing a Key Person

Prior ARC approval is required to change in a key person specified in the grant application or the 

grant agreement. Your State Program Manager should be copied on the request.

Reducing Engagement

Prior ARC approval is required if you disengage from your ARC project for more than three months, 

or reduce by 25 percent the time devoted to the project. Your State Program Manager should be 

copied on the request.

Changes in Cost Share/Match

Prior ARC approval is required for any changes to the approved cost-share or match provided.

Modifying the Budget of Your ARC Project

Prior ARC approval is required for changes to major line items when the grant amount exceeds 

$100,000 and the total proposed transfer exceeds ten percent of the project’s total approved 

budget. To request a budget change, submit a budget revision worksheet and narrative 

justification to the ARC project coordinator and State Program Manager. Note that the 10 percent 

cap on budget changes is cumulative over the life of the project and that new budget line items 

cannot be created.

The State Program Manager must concur with the request before ARC will consider a budget 

change request. Budget changes that involve substantial revision to the scope of work or 

objectives of the project regardless of the grant amount or amount of money being moved always 

require prior ARC approval.

Copies of minor budget revisions should be sent to ARC so that files will reflect the correct budget 

at all times. A budget revision request worksheet is available on ARC’s website.

Other Changes to an ARC Project

Generally, minor project extensions and budget revisions can be approved by the ARC project 

coordinator. Requests for substantial changes to a project’s scope of work must be reviewed and 

approved in a process that is similar to the review of the original application.

The State Program Manager must concur with the request before ARC will consider a project 

revision request.

To request a change to an ARC project, describe in detail the reason for adding, modifying, or 

deleting an activity. Include information explaining any revisions to the expected outcomes that 

would result from the proposed change(s).

 
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Record Keeping and Audits 

Office of Management and Budget Guidance/Federal Regulations

ARC grants must be administered in accordance with federal regulations promulgated by the 

Office of Management and Budget at Title 2 of the Code of Federal Regulations, Part 200, 

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal

Awards. The grantee is expected to be familiar with, and make sure that the project adheres to, 

these regulations. The regulations are occasionally revised. It is recommended to access the 

regulations at www.ecfr.gov, which is maintained by the U.S. government and updated regularly. 

You may order hard copies of the regulations directly from the Office of Management and 

Budget by telephoning that office at 202-395-7332.

Audit Requirements for ARC Grants and Subgrants

Grantees and subgrantees must maintain accurate and complete records relating to ARC 

awards and subawards, and make these available to ARC upon request, or for audit, as 

necessary, by the ARC Office of Inspector General or the Government Accountability Office. Each 

year, ARC’s Office of the Inspector General conducts random audits of selected ARC projects to 

ensure compliance with the Appalachian Regional Development Act, the ARC grant agreement, 

ARC policies and procedures, and federal regulations.

In addition, grantees and subgrantees that expend $750,000 or more of total federal awards 

(including any ARC grant) during their fiscal year must have a single or program-specific audit 

conducted for that year in accordance with Subpart F of 2 CFR Part 200. Grantees must ensure 

that their subgrantees comply with this audit requirement as applicable.

Common Audit Issues

If your organization is selected for an OIG audit, you are required to cooperate by providing all 

documentation and information requested. To get an idea of some common audit issues, you 

may access previous ARC OIG audit and inspection reports online at https://www.arc.gov/officeof-inspector-general/. Below are some potential audit issues to be aware of:

General financial management. Financial management systems must be sufficient to prepare 

reports, trace all funds, and ensure control and accountability over all property, funds, and assets.

Internal controls. Policies and procedures must provide reasonable assurance that the ARC 

grant will be managed in compliance with applicable statutes, regulations, and grant terms and 

conditions.

Separate Accounts. If your organization manages several grants, each grant must be accounted 

for separately, including activities, receipts, expenditures, and any matching fund 

documentation. Records must identify the source and use of funds provided for each grantfunded activity; no commingling of funds.

Documenting and identifying match. If your project will be using in-kind or third-party property 

or services for matching purposes, records should be maintained including a listing of sources 

and documentation showing that the contributions were valued according to federal cost 

principles at 2 CFR Part 200, Subpart E, and 2 CFR 200.306, e.g., appraisals, evidence of local rates 
Appalachian Regional Commission, February 2020 Page 13

of pay, etc. Documents such as invoices, volunteer time sheets, employee pay records, receipts, 

etc. should support all services donated.

Procurement. Written procurement policies and procedures should reflect requirements in 

federal regulations at 2 CFR 200.317-326, including (for grantees that are not state agencies) 

requirements relating to competition, standards of conduct prohibiting conflicts of interest, and 

cost and price analyses.

Direct/Indirect Costs. With a few exceptions, indirect costs charged to an ARC project must be 

pursuant to (a) a federally negotiated indirect cost rate or (b) the de minimis rate provided in 

federal regulations, as documented in writing. The rate must be listed in the approved ARC 

budget. Indirect and direct costs must be treated consistently.

Equipment and Property. Written equipment management and maintenance procedures must 

be followed, according to federal regulations and ARC requirements, including inventory 

requirements, filing of a notice of federal interest, and proper use.

Costs with respect to travel. Travel claims should follow written policies of the grantee when 

consistent with federal regulations at 2 CFR Part 200, including but not limited to 2 CFR 200.474. 

Invoices should support costs and expenditures.

Timeframe of eligible expenses. Expenses charged to the ARC project must be incurred during 

the grant period of performance. As noted previously, any grant period extensions must be 

approved by ARC before the grant period expires.

Support of Salaries and Wages. All documentation relating to salaries and wages charged to 

your ARC grant should be maintained. Salaries and wages must reflect the actual activity of each 

employee, not a budget estimate.

Performance measures. Final reports should describe actual achievements rather than 

estimates, and tie objectives met to the objectives outlined in the grant agreement.

Allowable costs. All costs charged to your ARC grant must be allowable under federal cost 

principles, Subpart E to 2 CFR Part 200.

Performance period. All costs charged to your ARC grant must be incurred during the period of 

performance, not before or after.
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After Project Completion 

Project Close-Out

After your project is complete you must submit a final narrative report and final financial 

reports. The ARC project coordinator will prepare closeout documentation. You will receive 

an email notification when the project has been closed by ARC.

Post-Closeout Obligations

You must promptly liquidate all obligations incurred under your ARC grant and promptly 

return any unused advance payments to ARC.

You must account for any real property or equipment purchased or improved with, or used 

as match for, your ARC grant, in accordance with 2 CFR 200.310 Insurance coverage through

200.316 Property trust relationship.

Program income is not required to be reported after a project is closed out.

Validation Visits and Other Post Award Activities with ARC

You may have other opportunities to share the success of your project if it is selected for a 

validation visit by ARC staff or if the project is selected to participate in an independent 

program evaluation. Grantees are required to comply with requests for information at these 

times even after the project is closed.

ARC’s project investments are tracked in a variety of ways after a project is closed, including:

Validation Visits – ARC staff visit approximately 50 projects annually. The visits help ARC to 

assess the impact of its investments and verify reported performance measures. Selected 

projects are visited after the ARC project is closed. Such visits may occur up to 5 years after 

project closeout. ARC Code chapter 8.9 requires grantees and subgrantees to cooperate with 

ARC’s evaluators, e.g. by providing the documents requested and participating in interviews.

Program Evaluations – Program evaluations are performed by an outside contractor, and 

required by Congress. Program evaluations often involve large numbers of ARC grantees 

currently or formerly involved in similar types of activities, such as infrastructure, education, 

business development, etc.

Inspector General Audits, Inspections, and Investigations – The Office of Inspector General 

provides independent and objective audits and investigations relating to agency programs 

and operations, as set forth in the Inspector General Act of 1978.