POST-AWARD COMPLIANCE CHECKLIST

EDA Economic Development Support: Compliance Requirements

What you must do after you win this award — administered by Economic Development Administration · Federal Program.

8
Total requirements
5
Clawback-risk items
8
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Reporting: Failure to report GPRA metrics may trigger withholding of final payment or future funding restrictions
  • Financial & Cost Eligibility: Inadequate financial records result in questioned costs, audit findings, and potential clawback of questioned amounts
  • Recordkeeping: Missing or inadequate documentation results in all questioned costs being disallowed and audit findings
  • Other Obligations: Unauthorized encumbrance of grant-funded property results in immediate clawback of project funds or entire award
  • Environmental: Failure to obtain environmental clearance or violating historic preservation requirements results in project suspension, cost disallowance, and clawback
  • Financial & Cost Eligibility: Failure to disclose budget deviations or inaccurate financial reporting triggers audit findings and potential cost disallowance
  • Financial & Cost Eligibility: Expenditures for unapproved scope changes or budget deviations are questioned costs subject to disallowance
  • Financial & Cost Eligibility: Failure to report real property status may trigger suspension of draws or recapture of grant funds

Reporting

  • Clawback riskSemi Annual

    Grantees must report GPRA performance data measuring jobs created, strategies developed, and partnerships formed. Construction awardees submit Form ED-915; non-construction awardees submit electronic questionnaires semi-annually during project activity and annually for 5 years post-completion.

    Deadline: Semi-annually while grant is active, then annually for 5 years after completion

    Source: EDA Managing Your EDA Grant page; 2 CFR 200.328-329

Financial & Cost Eligibility

  • Clawback riskOngoing

    Awardee must establish and maintain financial management systems with separate accounts for each federal award, containing agency name, program name, Assistance Listing number, award ID, and pass-through entity identification. Records must track all Federal funds, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest.

    Deadline: Maintain continuously throughout award period and retention period

    Source: 2 CFR 200.302(b)(1)-(3)

  • HighOngoing

    Awardee must provide accurate, current, and complete disclosure of financial results in accordance with 2 CFR 200.328 and 200.329, including deviations from approved budget or project scope.

    Deadline: As required by grant agreement terms and conditions

    Source: 2 CFR 200.302(b)(2); 2 CFR 200.329

  • HighEvent Driven

    Awardee must obtain prior approval from EDA before making budget and program plan revisions, including changes to project scope or project objectives.

    Deadline: Request approval before implementing changes

    Source: 2 CFR 200.329; EDA grant agreement terms

  • MediumAnnual

    Real property purchased wholly or partially with grant funds requires annual status reporting to the Federal awarding agency unless the Federal interest extends 15 years or more (in which case less frequent reporting may be permitted).

    Deadline: Annually, unless agency specifies otherwise for long-term interest properties

    Source: 2 CFR 200, Real Property Reporting provisions; EDA construction grant requirements per 13 CFR 314.6

Environmental

  • Clawback riskOne Time

    Projects receiving EDA funding are subject to environmental review and historic preservation compliance. Projects must demonstrate compliance with applicable environmental and historic preservation statutes and regulations.

    Deadline: Prior to project completion; environmental assessments completed before commencement of ground-disturbing activities

    Source: EDA grant process documentation (10 CFR, NEPA); PWEDA compliance requirements

Recordkeeping

  • Clawback riskOngoing

    Awardee must maintain records sufficient to permit preparation of required reports and to trace Federal funds to expenditures adequate to establish compliance with Federal statutes, regulations, and award terms.

    Deadline: Maintain throughout grant period and per 2 CFR 200.333 retention requirements (typically 3 years after final expenditure)

    Source: 2 CFR 200.302(a)

Other Obligations

  • Clawback riskOngoing

    Property acquired or improved with grant funds for construction projects cannot be mortgaged or encumbered except to secure a grant or loan by a State, other Federal agency, or public body participating in the project, unless EDA waiver is obtained.

    Deadline: Applies throughout ownership period of the property

    Source: 13 CFR 314.6

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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 Economic Development Administration.