POST-AWARD COMPLIANCE CHECKLIST

EPA Brownfields Assessment Grant: Compliance Requirements

What you must do after you win this award — administered by US Environmental Protection Agency · Federal Program.

10
Total requirements
5
Clawback-risk items
10
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to meet sufficient progress requirement may result in grant termination under 2 CFR § 200.339 or other enforcement actions
  • Reporting: Missing or non-compliant AAI deliverables may result in disallowed assessment costs and loss of grant funds for that site
  • Recordkeeping: Sampling conducted without prior EPA-approved QAPP will result in disallowed costs for that sampling work
  • Procurement & Vendor Rules: Non-competitive or undisclosed procurement may result in disallowed contractor costs and clawback of related grant funds
  • Environmental: Work conducted without prior EPA consultation and approval for NHPA/ESA compliance may result in disallowed costs and federal enforcement action
  • Reporting: Missing or late reports may trigger financial audit holds and delay final grant closeout and payment release
  • Recordkeeping: Failure to report accomplishments in ACRES may result in loss of performance credit and inability to demonstrate sufficient progress
  • Environmental: Failure to protect community from contaminant exposure may result in costs disallowed under health/safety noncompliance and potential EPA enforcement action
  • Financial & Cost Eligibility: Failure to meet the minimum 10-site assessment threshold may result in clawback of grant funds or denial of future EPA grant awards
  • Reporting: Failure to provide leveraged resource information may affect future EPA grant eligibility and performance metrics

Reporting

  • Clawback riskEvent Driven

    Recipients must submit All Appropriate Inquiries (AAI) reports to EPA Project Officers with a completed Reporting Requirements Checklist (provided by EPA) as required deliverables under the assessment cooperative agreement.

    Deadline: As each site assessment is completed and submitted as a deliverable

    Source: EPA Programmatic Requirements for Brownfield Grants; 40 CFR Part 312; 5 U.S.C. § 301

  • HighQuarterly

    Recipients must submit quarterly progress reports within 30 days of each quarter end (reporting periods vary by region) and closeout reports no later than 120 days after the end of the cooperative agreement period of performance.

    Deadline: 30 days after each quarter end; final closeout 120 days after agreement end

    Source: EPA New England Grantee Forms & Reporting; Standard EPA Grant Reporting Requirements

  • MediumEvent Driven

    Recipients must provide post-grant information to EPA on leveraged resources (non-EPA funds) obtained as a result of EPA-funded activities, which EPA may request well after the period of performance has ended.

    Deadline: EPA may request this information at any time, including after grant period ends

    Source: EPA Programmatic Requirements; Government Performance and Results Act (GPRA)

Financial & Cost Eligibility

  • Clawback riskOne Time

    For Assessment Grants, recipients must demonstrate sufficient progress by drawing down and obligating at least 35% of awarded funds to eligible activities by 18 months from the date of award.

    Deadline: 18 months from award date

    Source: EPA Programmatic Requirements for Brownfield Grants; FY26 Assessment Grant Guidelines (EPA-I-OLEM-OBLR-25-05 and 25-07)

  • HighOngoing

    Recipients must assess a minimum of 10 brownfield sites; additional sites may be selected throughout the period of performance if they meet site eligibility criteria.

    Deadline: By end of grant period of performance

    Source: FY26 Guidelines for Brownfield Assessment Grants (EPA-I-OLEM-OBLR-25-05 and 25-07)

Procurement & Vendor Rules

  • Clawback riskOne Time

    Recipients must comply with federal competitive procurement requirements (2 CFR 200 Subpart D) for all contractors and subrecipients. If a contractor was selected prior to application submission, recipients must disclose this and the procurement procedures followed.

    Deadline: Disclosure required in application; ongoing compliance for all contractor selections

    Source: FY26 Guidelines Section 4.D; 2 CFR 200.317-200.327

Environmental

  • Clawback riskEvent Driven

    Recipients must consult with EPA prior to conducting any on-site activity (invasive sampling, cleanup) that may affect historic properties or threatened/endangered species to ensure compliance with National Historic Preservation Act § 106 and Endangered Species Act § 7(a)(2).

    Deadline: Before any on-site invasive work begins

    Source: EPA Programmatic Requirements for Brownfield Grants; NHPA § 106; ESA § 7(a)(2)

  • HighOngoing

    Recipients must protect all nearby populations, including sensitive populations in the target community, from contaminants during assessment and cleanup work by implementing procedures to mitigate potential exposure.

    Deadline: Throughout all grant-funded on-site activities

    Source: EPA Programmatic Requirements for Brownfield Grants

Recordkeeping

  • Clawback riskEvent Driven

    Recipients must submit a Quality Assurance Project Plan (QAPP) to EPA for approval prior to collecting any environmental samples as part of assessment or cleanup work.

    Deadline: Prior to commencement of any environmental sampling activities

    Source: EPA Programmatic Requirements; 2 CFR § 1500.11

  • HighOngoing

    Recipients must enter accomplishment data into the ACRES (Assessment, Cleanup and Redevelopment Exchange System) database as soon as accomplishments occur, documenting assessed properties and cleanup completion using the Property Profile Form.

    Deadline: As soon as each accomplishment occurs; ongoing throughout grant period

    Source: EPA Grant Recipient Reporting; ACRES 6.0 System Requirements

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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 Environmental Protection Agency.