POST-AWARD COMPLIANCE CHECKLIST

DOT RAISE Transportation Grants: Compliance Requirements

What you must do after you win this award — administered by US Department of Transportation · Federal Program.

10
Total requirements
4
Clawback-risk items
10
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: All costs incurred pre-award under 23 U.S.C. 115 (advance construction) or FTA LONP will be disallowed and cannot be charged to the grant
  • Financial & Cost Eligibility: Costs that violate 2 CFR 200 Subpart E (e.g., unallowable salary rates, fringe benefits, indirect costs) will be disallowed and subject to clawback
  • Environmental: Costs incurred without NEPA clearance are ineligible; construction/implementation costs can be disallowed and clawed back
  • Labor & Wage: Underpayment of prevailing wages or failure to comply with wage requirements results in disallowance of labor costs and potential back-pay liability
  • Recordkeeping: Missing or inadequate records can result in audit disallowances, penalties, and inability to support cost reimbursement claims
  • Reporting: Failure to submit FFR timely or with inaccurate data can trigger audit exceptions, payment holds, or grant termination
  • Reporting: Failure to report sub-awards can result in penalties and disallowance of sub-award costs; federal transparency violations
  • Procurement & Vendor Rules: Sole-source procurements without justification, non-competitive purchases, or inadequate vendor documentation will be disallowed
  • Other Obligations: Lapsed or inactive SAM registration can result in payment suspensions, grant termination, or ineligibility for future awards
  • Reporting: Failure to complete project deliverables or provide closeout documentation can result in clawback of unspent/undelivered funds

Reporting

  • HighAnnual

    Awardee must submit Federal Financial Reports (FFR) annually or as specified in grant agreement showing project expenditures, budget status, and financial progress.

    Deadline: Due annually; specific deadline determined by grant agreement and OMB-required reporting systems

    Source: Uniform Guidance 2 CFR 200, standard federal grant reporting requirement; referenced in comparable DOT programs

  • HighEvent Driven

    Awardee must report sub-awards of $30,000 or more to subrecipients via Federal Funding Accountability and Transparency Act (FFATA) system within 30 days of award.

    Deadline: Within 30 days of each sub-award of $30,000 or more to a subrecipient

    Source: FFATA requirements (31 U.S.C. 6101 et seq.), standard federal pass-through requirement

  • HighOne Time

    Awardee must provide documented evidence of project completion and delivery of all deliverables within the grant agreement period of performance; final project status and financial closeout report required.

    Deadline: Due upon project completion and no later than end of period of performance; 90-day final closeout reporting window

    Source: Standard DOT grant agreement requirement; referenced in comparable programs (SS4A NOFO Section D.8.i)

Financial & Cost Eligibility

  • Clawback riskOne Time

    Pre-award costs incurred under advance construction or FTA Letter of No Prejudice prior to official award announcement cannot be charged to RAISE grant funds; only post-award costs directly necessary for efficient grant agreement performance are eligible.

    Deadline: Determination made at time of award announcement; costs incurred before announcement are ineligible

    Source: FY 2025 RAISE NOFO, pp. 1-2 (pre-award cost definition and exclusions)

  • Clawback riskOngoing

    All grant expenditures must comply with the cost principles in 2 CFR Part 200, Subpart E (Uniform Guidance cost allowability rules).

    Deadline: Applies throughout the entire period of performance to all reimbursement requests

    Source: Uniform Guidance 2 CFR 200, referenced in comparable DOT grant programs (SS4A, NOFO Section D)

Procurement & Vendor Rules

  • HighEvent Driven

    All project procurement activities must comply with 2 CFR 200.317-200.326 (Uniform Guidance procurement standards), including competitive bidding, documentation, and vendor accountability.

    Deadline: Applies to all procurement actions; competitive process must be documented before purchase commitment

    Source: 2 CFR 200.317-326; standard federal grant procurement requirement

Labor & Wage

  • Clawback riskOngoing

    All construction work funded by RAISE grants must comply with federal prevailing wage requirements (Davis-Bacon Act for highway projects under 23 U.S.C., or FTA prevailing wage rules for transit).

    Deadline: Prevailing wage rates apply to all eligible construction labor; compliance monitored throughout construction phase

    Source: 40 U.S.C. 3141-3167 (Davis-Bacon Act); standard DOT grant requirement for surface transportation construction

Environmental

  • Clawback riskOne Time

    Projects must comply with National Environmental Policy Act (NEPA) requirements; awardee must provide documented evidence of NEPA compliance (EA, EIS, or categorical exclusion) prior to final approval of project.

    Deadline: NEPA clearance required before project implementation; documented evidence must be provided to DOT

    Source: 42 U.S.C. 4321 et seq. (NEPA); standard DOT grant requirement referenced in NOFOs

Recordkeeping

  • HighOngoing

    Awardees must maintain all financial records, supporting documentation, and project files in accessible format; records must be retained for minimum 3 years after final expenditure report per 2 CFR 200.334 (Uniform Guidance).

    Deadline: Three-year retention period begins after submission of final financial report; applies across all grant lifecycle

    Source: 2 CFR 200.334 (records retention); standard federal grant requirement

Other Obligations

  • HighAnnual

    Awardee must maintain and report its registration and UEI (Unique Entity Identifier) in System for Award Management (SAM.gov) throughout grant period; must update and revalidate annually.

    Deadline: SAM registration must be active at time of award and revalidated at least annually; any changes must be reported to DOT

    Source: Federal Acquisition Regulation (FAR) and Uniform Guidance 2 CFR 200; standard federal award requirement

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This checklist is compiled from official program sources and general grant-management rules for informational purposes. Final compliance obligations are governed by your specific grant agreement and the administering agency — always verify with US Department of Transportation.