POST-AWARD COMPLIANCE CHECKLIST

EPA Brownfields Revolving Loan Fund: Compliance Requirements

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

9
Total requirements
3
Clawback-risk items
9
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to meet 50/50 split triggers disallowance of excess programmatic cost spending
  • Financial & Cost Eligibility: Improper management or failure to return program income upon termination triggers clawback and disallowed costs
  • Other Obligations: Failure to meet sufficient progress triggers corrective action plan requirement or grant termination under 2 CFR § 200.339
  • Reporting: Failure to report may lead to grant suspension or termination under 2 CFR § 200.339
  • Reporting: Failure to closeout properly may result in costs being disallowed or withheld from final payment
  • Procurement & Vendor Rules: Procurements conducted without EPA advance review may result in disallowance of associated costs
  • Reporting: Non-compliance with post-closeout reporting may trigger enforcement action or clawback of program income
  • Environmental: Sampling conducted without EPA-approved QAPP results in disallowance of associated costs
  • Reporting: Failure to report MBE/WBE compliance may affect future funding eligibility

Reporting

  • HighQuarterly

    RLF awardees must submit quarterly reports 30 days after each reporting period ends. Reports are entered into EPA's ACRES (Assessment, Cleanup and Redevelopment Exchange System) database.

    Deadline: 30 days after quarter end

    Source: EPA Grantee Forms & Reporting for Brownfields and Land Revitalization (New England region); 14 CFR 200 (anticipated)

  • HighOne Time

    Awardees must submit closeout reports no later than 120 days after the end of the cooperative agreement period of performance, including final technical reports summarizing all grant activities.

    Deadline: within 120 days of agreement end date

    Source: EPA Grantee Forms & Reporting for Brownfields (New England region); 14-12, 14-13

  • HighOngoing

    Recipients commit to compliance with certain reporting requirements even after the RLF Grant is formally closed, operating under continuing post-closeout cooperative agreement terms.

    Deadline: ongoing after grant closeout

    Source: EPA Brownfields RLF Grants page; 1-4, 1-8, 11-5, 20-3

  • MediumQuarterly

    Recipients must report Minority-Owned Business Enterprises (MBE) and Women-Owned Business Enterprises (WBE) participation 30 days after each reporting period ends using EPA Form 5700-52A.

    Deadline: 30 days after quarter end

    Source: EPA Grantee Forms & Reporting for Brownfields (New England region); 14-3, 14-8, 14-10

Financial & Cost Eligibility

  • Clawback riskOne Time

    At least 50% of awarded EPA RLF funds and associated cost share must be used for loans to cleanup eligible brownfield sites; the remaining funds may be used for eligible programmatic costs.

    Deadline: by end of cooperative agreement period

    Source: EPA Brownfields RLF FAQs (June 30, 2025); 5-2

  • Clawback riskOngoing

    Recipients must commit to properly manage program income generated by the RLF program in perpetuity, unless they formally terminate the agreement and return all program income to EPA.

    Deadline: continuously throughout life of agreement and post-closeout

    Source: EPA Brownfields RLF Grants main page; 1-9, 11-7, 20-6

Procurement & Vendor Rules

  • HighEvent Driven

    Recipients must submit proposed procurements for EPA review in advance, in accordance with 2 CFR § 200.325, including requests for proposals, invitations for bids, and scopes of work.

    Deadline: prior to solicitation issuance

    Source: FY25 RLF NOFO (EPA); 19-5, 19-16

Environmental

  • HighEvent Driven

    If environmental samples are collected during any brownfields activity, recipients must submit a Quality Assurance Project Plan (QAPP) to EPA for approval prior to sample collection, per 2 CFR § 1500.11.

    Deadline: prior to collection of environmental samples

    Source: EPA Programmatic Requirements for Brownfield Grants; 18-16, 18-17

Other Obligations

  • Clawback riskOne Time

    RLF recipients must demonstrate sufficient progress 2 years from award date by making at least one loan/subgrant, or by hiring key personnel, establishing and advertising the RLF, and developing potential loans/subgrants.

    Deadline: by 2-year anniversary of award

    Source: EPA Programmatic Requirements for Brownfield Grants; 18-10 to 18-14

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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.