POST-AWARD COMPLIANCE CHECKLIST

EDA Public Works and Economic Adjustment: Compliance Requirements

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

10
Total requirements
6
Clawback-risk items
10
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to report expenditures or misreporting federal/match spend triggers cost disallowance; missing match documentation results in clawback of federal funds proportional to shortfall
  • Financial & Cost Eligibility: Inability to produce supporting documentation for claimed costs results in audit disallowance; incomplete records trigger questioned costs and potential clawback
  • Financial & Cost Eligibility: Insufficient match paid or documented results in proportional reduction of federal reimbursement; failure to exhaust program income before drawdowns causes loss of ability to draw remaining federal grant
  • Procurement & Vendor Rules: Procurement conducted without competitive bidding or EDA approval results in complete disallowance of contract costs and potential clawback of project funds
  • Environmental: Construction or activity without required environmental compliance results in complete disallowance of project costs and potential forced reversal/remediation at awardee expense
  • Other Obligations: False certification triggers liability under 31 USC 3729 (False Claims Act); discriminatory use of funds results in fund clawback and potential DOJ enforcement
  • Reporting: Failure to submit ED-915 or provide documented evidence of outcomes prevents grant closeout; false certifications create liability under 31 USC 3729
  • Recordkeeping: Without final inspection and EDA acceptance, project cannot close out and federal funds cannot be fully released from grant; costs incurred after final inspection may be disallowed
  • Other Obligations: Scope changes without EDA approval result in disallowance of unauthorized costs; significant delay or abandonment triggers clawback of unspent federal funds
  • Other Obligations: Audit findings for questioned costs or noncompliance result in cost disallowance; refusal to cooperate with audit triggers grant suspension and fund clawback

Reporting

  • HighOne Time

    Awardee must submit ED-915 GPRA Data Collection Form documenting project outcomes (jobs created/retained, private investment leveraged, wages), with certifications verifying accuracy. Data must be collected and reported for entire project period.

    Deadline: Final report due at project closeout

    Source: EDA grantee information; NOFO Section F (reporting requirements); OMB No. 0610-0088

Financial & Cost Eligibility

  • Clawback riskQuarterly

    Awardee must submit SF-425 Federal Financial Report (FFR) for each reporting period, documenting all project expenditures, federal and non-federal match spent, and indirect costs charged to the award. Final report due within 120 days of project completion.

    Deadline: Quarterly during project period; final report within 120 days of project end date

    Source: EDA grant agreement & 2 CFR 200.328; EDA SF-425 instructions

  • Clawback riskOngoing

    Awardee must maintain and make available all financial records, supporting documents, statistical reports, and programmatic records for audit. Records must be kept for minimum 3 years after project completion.

    Deadline: Maintain throughout project period and 3 years post-closeout

    Source: 2 CFR 200.333; EDA grant agreement; Federal Grants Wire 19-1,19-5

  • Clawback riskOngoing

    Awardee must ensure non-federal match equal to the percentage specified in award (typically 40% for standard Public Works) is actually paid and documented; unspent program income must be used before requesting additional federal funds.

    Deadline: Match must be spent proportionally with federal funds throughout project period

    Source: NOFO 20-6 to 20-7; EDA SF-425 instructions 14-32; 2 CFR 200.307

Procurement & Vendor Rules

  • Clawback riskEvent Driven

    For construction projects, awardee must conduct competitive procurement processes compliant with 2 CFR 200.320 and EDA requirements, obtain EDA approval of bid documents before advertising, and obtain EDA concurrence at bid opening before awarding contracts.

    Deadline: Before bid advertisement, at bid opening, and before contract execution

    Source: 13 CFR 305.14-305.16; 2 CFR 200.320-323

Environmental

  • Clawback riskEvent Driven

    Awardee must comply with all applicable environmental statutes and executive orders (NEPA, CWA, CAA, etc.). Before construction begins, awardee must obtain and provide EDA with evidence of all required environmental permits and clearances.

    Deadline: Before project bid advertisement and construction start

    Source: 2 CFR 200.305; 13 CFR 314; PWEDA 42 USC 3144

Recordkeeping

  • HighOne Time

    For construction projects with EDA funding, awardee must obtain EDA final inspection approval, schedule final inspection when project is complete, notify EDA of results, and obtain EDA acceptance of completed work before project closeout.

    Deadline: Upon project completion; final inspection scheduled by awardee with EDA notification required

    Source: 13 CFR 305.20; EDA Construction Grant Post Approval Process

Other Obligations

  • Clawback riskOne Time

    Awardee must certify compliance with federal antidiscrimination laws (Title VI, Section 504, ADA, Executive Order 14173) and, if over $5 million or a corporation, provide additional certifications regarding executive compensation, tax compliance, and regulatory violations.

    Deadline: At application/award time; updated certifications if material changes

    Source: NOFO Section F (certifications); 2 CFR 200.113; EO 14173

  • HighOngoing

    Awardee must implement project according to approved scope of work and timeline specified in grant award; any material changes to project scope, budget, or timeline require prior written EDA approval; awardee must notify EDA immediately if unable to meet project schedule.

    Deadline: Continuous; must notify EDA before timeline slippage

    Source: 13 CFR 305.24-305.25; NOFO award conditions

  • HighEvent Driven

    Awardee is subject to audit by EDA, DOC Office of Inspector General, or other auditors. Awardee must comply with audit requests, provide requested documentation within reasonable timeframe, and implement corrective actions for identified deficiencies.

    Deadline: Upon audit notification; corrective actions due per audit findings

    Source: 2 CFR 200.500-521; Federal Grants Wire 19-4; EDA grant agreement

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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.