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ACING AN AUDIT: MANAGING YOUR RLF GRANT FILE Audio 866-299-3188 Code: 202 566 2773. EPA Rlf webinar. October 31, 2013. ( Section A )- Acing an Audit: Grants File Management-R4 RLF PO Perspective ( Section B )- Acing an Audit: Grants File Management-EPA R4 RLF Grantee’s Perspective.

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acing an audit managing your rlf grant file audio 866 299 3188 code 202 566 2773
ACING AN AUDIT:

MANAGING YOUR RLF GRANT FILE

Audio

866-299-3188

Code: 202 566 2773

EPA Rlf webinar

October 31, 2013

purpose of presentation

(Section A)- Acing an Audit: Grants File Management-R4 RLF PO Perspective

  • (Section B)- Acing an Audit: Grants File Management-EPA R4 RLF Grantee’s Perspective
Purpose of Presentation
get organized
Get Organized
  • RLF PO
    • Overseeing and monitoring the RLF Grant CA, and
    • Ensuring all financial and environmental cleanups requirements are met
  • Best “First” Approach
    • Setting up Six Part Folder
region 4 rlf po s

We wear Three hats:

    • PO Lead
    • Grants Lead
    • Technical Lead
Region 4 RLF PO’s
six part folder

Pre-Award Documents - PART 1

  • Post-Award Documents - PART 2
  • Progress Reports/Deliverables -PART 3
  • Post-Award Monitoring Doc’s - PART 4
  • Correspondences (Internal/External) - PART 5
  • Brownfields Proposal Information-PART 6
Six Part Folder
part 1 pre award checklist
PART 1- (Pre-Award) Checklist
  • Grant Application/Workplan
  • Workplan Comments/Approval
  • CN/FR/Cost Analysis
  • Competition Documents, etc.
part 2 post award checklist
PART 2- (Post-Award) Checklist
  • Signed Award Agreement with T&C’s
  • Change Requests to CA/Amendments
  • Closeout Documents/Memos
part 3 progress reports deliverables checklist
PART 3- (Progress Reports/Deliverables) Checklist

LEGEND:

1/ Measuring Success/Tracking Documents

2/ Program Related Documents

3/ Cleanup Planning Documents

part 4 post award monitoring doc s checklist
PART 4- (Post award monitoring Doc’s) Checklist
  • Baseline Monitoring Reports
  • Advance Monitoring Reports (Including Davis Bacon Compliance)
  • Semi annual Docs (MBE/WBE Rpts)
  • Annual Rpts (FFR)
part 5 correspondences checklist
PART 5- (Correspondences) Checklist
  • Emails/Letters
  • Faxes
  • Hand Written Notes, Memos, Etc.
part 6 brownfields proposal info checklist
PART 6- (Brownfields Proposal info) Checklist
  • Original Proposal
  • Congratulatory Letter
  • Fact Sheet
rlf checklist

Five part file system:

  • Proposal
  • Award
  • Program
  • Administrative Record / Project
  • Audit
RLF Checklist
proposal file

Contains:

  • Original EPA Grant Proposal
  • List of Brownfield Sites
  • Project Partners
Proposal File
award file

Contains:

  • EPA Grant Application
  • EPA-Approved Workplan
  • Signed Cooperative Agreement
  • Detailed project budget by expense categories
  • Project Timeline
Award File
program file

Contains:

RLF Loan Program Materials:

  • Loan Policies and Procedures Plan
  • Marketing Plan with Collateral Materials
  • RLF Loan/Subgrant Application Forms
  • Loan/Subgrant Agreements
  • Site Access Agreement
  • Partner MOUs
  • EPA Property Profile Form

Program Manager Materials:

  • Sample Quarterly Report Template
  • Financial Report Template
  • MBE/WBE Reports
  • RFQ Process Documentation
  • List of approved consultants
  • Team contact list
  • Consultant contact list
  • DOL Wage Determination, including interviews and certified payrolls
Program File
administrative record project file

Contains:

  • Brownfield Site Information (Legal, designation, Brownfield Site Rehabilitation Agreement (BSRA), etc)
  • ABCA
  • Assessment Reports
  • QAPP
  • Public Involvement Plan
  • RLF Match (Grantee and/or Loan or Subgrantee)
  • Qualified Environmental Professional
  • Cleanup Budget
  • Cleanup Contract
  • Cleanup Contractor Insurance
  • Loan/Grant Commitment Letter
  • Loan/Grant Agreement
  • Site Photos (Before and After)
Administrative Record/Project File
audit file

Contains:

  • Written Policies and Procedures for:

Procurements with respect to purchases, goods and services, consultant contracts and sub-awards.

Audit File
program considerations

Cost Share:

  • Cost share can be met by cooperative agreement recipient and/or loan recipient
  • If borne by loan recipient, the loan application should reflect local match
Program Considerations
program considerations1

Administrative Costs:

  • Only eligible programmatic costs can be reimbursed by EPA
  • Administrative costs are not allowed
  • Other funds to consider to offset programmatic expenses include:
    • Other federal grants such as:
    • EDA District Planning Grants / Public Works Grants
    • HUD Community Planning Challenge Grants
Program Considerations
program considerations2

ACRES/Financial Reports:

  • Update ACRES on a regular basis but especially after site milestones:
    • Completion of Phase I ESA/Phase II ESA
    • Completion of Site Assessment Report
    • Receipt of site closure order/letter from your state department of environmental protection/regulation
  • Consultants hired to complete assessments and/or site cleanup should be required to update ACRES for your agency
  • Agency program manager should review ACRES update after input by Consultant and request corrections, if needed
  • Financial Reports:
    • File once a year, program manager completes with finance manager
Program Considerations
contact information
Contact Information
  • Greg Vaday
  • Economic Development Coordinator
  • Treasure Coast Regional Planning Council
  • (772) 221-4060
  • Email: gvaday@tcrpc.org
  • Website: www.tcrpc.org
checklist

Application

EPA Property Profile Form (WAM)

Legal Property Description

Assessment Reports

Brownfields Agreement (if applicable)

Final Remedial Action Plan

ABCA

30-day Public Review Notice

QAPP

Public Information Plan

ESA Consultation

SHPO Consultation

  • Match
  • Davis Bacon Wage Rates
  • Qualified Environmental Professional (QEP)
  • Cleanup Budget
  • Cleanup Contract
  • Contractor Insurance
  • Loan/Grant Commitment Letter
  • Loan/Grant Agreement
  • Promissory Note
  • Photos
Checklist
administrative record contents

News Releases

  • ABCA
  • Remedial Action Plan
  • Community Involvement Plan (CIP)
  • Photos
  • Name & contact information of spokesperson for the project
  • Brownfields Agreement (if applicable)
  • Personal financial information- Not required*
Administrative Record Contents
sample forms 30 day public review

Please run the below ad one time on (date) in the NON-LEGAL SECTION of the Classifieds. Place a border around the ad and bold the lead lines. The ad should be created in the most economical size. Please bill to Sunshine Ventures, LLC, reference should be EPA Brownfields.

Analysis of Brownfields Cleanup Alternatives (ABCA) and other documents for the Sunshine Ventures, LLC Project can be viewed at:

Downtown Library Annex

123 Main Street

Anytown, USA

Questions and comments concerning the plan should be directed to Sam Jones,

Sunshine Ventures, LLC

987 First Street

Anytown, USA

Phone: (101) 987-6543

Sample Forms- 30 Day Public Review
sample forms community involvement plan cip

Sunshine Ventures, LLC – Community Involvement

Plan for Sunshine Ventures Brownfields Cleanup Project

  • Overview of Project
  • Spokesperson & Administrative Record
  • Site Description & History
  • Community Involvement
  • Key Community Contacts
  • Local and elected officials
  • Media contacts and meeting places
  • Use the EPA template!
Sample Forms- Community Involvement Plan- CIP
esa consultation sample letter

Mr. Joe Jones

US Fish & Wildlife

Our agency (name) plans to use grant funds from the Environmental Protection Agency (EPA) to lend for Brownfields remediation activities at property located at _________ , North Carolina. The intended reuse of the property is _________________________________________.

The scope of work consists of ____________________________.

Please comment on this project as soon as possible concerning its possible impact on endangered species in the area. If you have questions or require additional information, please contact me at 101- 234-5678 or _(email)_________________________.

A location and site map is included for your reference.

Thank you for your time and cooperation.

ESA Consultation Sample Letter
shpo consultation letter sample

To: State Historic Preservation Office (or equivalent)

Our agency intends to use grant funds from the Environmental Protection Agency to lend for Brownfields cleanup activities at (site address).

Under the terms of our Brownfields grant, we are required to investigate through the appropriate state office what, if any, adverse impact our project activities may have on historic properties. We have researched the available history of this property and the adjacent properties, and we are of the opinion that our project activities would have no adverse impact on historic properties whatsoever.

We are formally requesting that your office investigate this matter and provide us with written communication relative to your position. Concurrence that assessment activities at this time will not have any effect on historic preservation in the area is appreciated. Please feel free to contact me if there is any additional information that we can provide to aid in your determination.

(continued)

SHPO Consultation Letter Sample
shpo consultation letter sample 2

Brief description of the site, including a description of the physical site characteristics such as vegetation, slope, the presence of any structures, and a brief history of the development of the site, if known. This could include such things as if the site was built on imported fill, or filled and graded.

Information in your files or reports as to whether the site or any part of it is listed on, or eligible for listing on, the National Register of Historic Places, and/or an Indian Reservation. Please include any correspondence with your State Historic Preservation Officer (SHPO).

Activity Information: provide EPA details of the kinds of activities that will occur, where they will occur, and what care will be taken to minimize any potential impacts.

If historic tax credits are part of the funding, the borrower will have necessary documentation.

SHPO Consultation Letter Sample (2)
sample commitment letter

Based upon the information supplied in your loan request for additional funding, the Loan Review Board has approved your request for a loan of $xxxxx. According to our internal policies, this loan will be made from a grant from the Environmental Protection Agency (EPA) Revolving Loan Fund Program.

The loan term shall be based on a thirty-year term with a 5-year full maturity rate. The interest rate shall be xxx percent (x%) fixed. Principal and interest are accrued and deferred until no later than July 1, 2013. Beginning July 1, 2013, monthly payments shall be in the amount of $xxx with the balance of the loan payable in full on July 1, 2018. Further, this loan offer is subject to the following additional terms and conditions:

The RBI RLF funds shall be used to pay for cleanup planning activities and for asbestos remediation activities at 505 Summer Hill Road, Anytown, USA.

Mr. Sam Jones will provide his unconditional personal guarantee and will provide a title policy for the property. Current business casualty/hazard insurance shall be maintained on Sunshine Ventures, LLC, in an amount sufficient to cover the total outstanding debt, with (Grantor- your name) named as loss payee.

All closing costs and recoding fees are the responsibility of the borrowers and shall be paid at the time of closing.

We are pleased to be able to support this exciting project.

Sample Commitment Letter
match report sample

Task 1: Community Involvement

Task 2 Establish RLF and Grant Program

Task 3 Operate RLF and Grant Program

Task 4: Market RLF and Grant Programs

Task 5: Cleanup & Redevelopment Planning

Task 6 Applicant Screening

Task 7 Other: Approximately 1.2% of total funds is allocated and needed for task overages and/or unforeseen and unplanned budgetary needs.

Task 8 Loans and Grants

Match Report Sample
finding match

Match= money, labor, material or services from a non-federal source.

  • Require the borrower to provide match.
  • Traditional financing to support the cleanup.
  • Non-profits can document time spent on the project (payroll, letter from finance office).
Finding Match
file folders just a suggestion
Section II

Section I

Application

Financials

Legal Description of Property

Executive Summary (project)

  • Assessment reports
  • Remedial Action Plan
  • ABCA
  • 30 day review
  • QAPP
  • ESA Consultation
  • SHPO Consultation
  • Community Involvement Plan
  • Brownfields Agreement *

Inside Cover

  • Checklist
File Folders- Just a Suggestion!
file folders just a suggestion1
Section II

Section I

Application

Financials

Legal Description of Property

Executive Summary (project)

  • Assessment reports
  • Remedial Action Plan
  • ABCA
  • 30 day review
  • QAPP
  • ESA Consultation
  • SHPO Consultation
  • Community Involvement Plan
  • Brownfields Agreement *

Inside Cover

  • Checklist
File Folders- Just a Suggestion!
file contents
Section IV

Section III

All funding commitments

Sources & Uses of Funds

Deed of Trust

Promissory Note

Personal Guarantees*

UCC Forms*

  • Davis Bacon Wage Rates
  • Employee Interview Forms
  • Payroll Reports

Section V

  • QEP Procurement Files
  • Cleanup Budget
  • Cleanup Contract
  • Contractor Insurance

Section VI

  • Invoices
  • Requests for Reimbursement
  • Backup Documents
File Contents
records retention

Maintain records for at least 3-10 years after submission of the final

expenditure report.

  • Keep all records of claims until resolved.
  • Obtain written approval from EPA prior to destroying any records.
  • If you operate the fund following closeout- KEEP the Records!
  • Negotiate the requirements with EPA.; they have access to these.
  • RLF grant records maintained by recipients are not subject to the

Federal Freedom of Information Act, 5 U.S.C. § 552.

  • Unless other federal, state, or local law applies, recipients are not required to permit public access to their records.
Records Retention
miscellaneous stuff

ACRES- new information should be entered when you make a new loan or subgrant.

  • Update when you pay an invoice, or
  • Update prior to preparing your quarterly reports.
  • Financial reports- done through our finance office; send match report to them.
  • LOSRC is a Regional Planning and Development Commission, organized pursuant to the NC General Statutes 158-8, et seq. and 153A-391, enabling LOSRC to operate a RLF Program.
Miscellaneous “Stuff”
slide44

Contact

Kate O’Hara

Senior Planner / BF Program Manager

Land-of-Sky Regional Council

339 New Leicester Hwy, Suite 140, Asheville, NC 28806

(828) 251-7454

kate@landofsky.org