POST-AWARD COMPLIANCE CHECKLIST

Historic Preservation Fund Grants: Compliance Requirements

What you must do after you win this award — administered by National Park Service · Federal Program.

8
Total requirements
4
Clawback-risk items
8
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Reporting: Failure to report can result in grant suspension and ineligibility for future awards; unexplained costs may be disallowed
  • Environmental: Work performed prior to Section 106 approval results in disallowed costs and mandatory project suspension; grant clawback possible
  • Ongoing Eligibility: Non-conforming work is ineligible; all costs for substandard preservation treatments may be disallowed and must be corrected at awardee expense
  • Financial & Cost Eligibility: Costs incurred after grant end date are non-allowable and will be disallowed; late final reports may trigger grant closeout delays and financial penalties
  • Recordkeeping: Failure to track/report equipment can result in questioned costs and audit findings; improper use of equipment constitutes cost disallowance
  • Procurement & Vendor Rules: Non-competitive or unapproved procurements result in disallowed costs; work performed by unqualified vendors is ineligible
  • Reporting: Work executed without prior NPS approval is ineligible; costs for non-approved work or revisions are disallowed
  • Recordkeeping: Failure to execute and submit required legal/administrative documents results in project incompleteness and cost disallowance for related work

Reporting

  • Clawback riskSemi Annual

    Submit interim reports every six months (unless modified in grant agreement) documenting project progress, accompanied by SF-425 Federal Financial Report and ASAP payment system drawdown history.

    Deadline: Every six months from award start unless grant agreement specifies otherwise

    Source: NPS Grant Reporting page; 2 CFR 200.329

  • HighEvent Driven

    Submit all required draft work products (architectural plans, specifications, documentation per grant scope) to NPS grant manager for review and written approval before proceeding to next project phase.

    Deadline: Submit drafts when ready; do not wait until interim report deadline; approval required before execution

    Source: NPS Grant Requirements page; grant agreement terms and conditions

Financial & Cost Eligibility

  • Clawback riskOne Time

    Complete and submit all final reporting within 120 days after the grant end date; no new costs may be incurred after the stated end date in the Notice of Award.

    Deadline: Final report due within 120 days of grant end date; no cost incurrence after stated end date

    Source: NPS Grant Reporting page; 2 CFR 200.344

Procurement & Vendor Rules

  • HighEvent Driven

    Obtain competitive bids for professional services (consulting, architectural, engineering) when required by grant agreement; vendor qualifications must be submitted to NPS grant manager for approval prior to commencing work.

    Deadline: Submit vendor qualifications before work begins; maintain procurement documentation throughout grant period

    Source: NPS Grant Reporting page; 2 CFR 200.320

Environmental

  • Clawback riskOne Time

    Obtain completion of Section 106 review and compliance determination from NPS prior to beginning any grant-assisted work on the project.

    Deadline: Must be complete before project work begins

    Source: NPS Compliance page (54 USC 306108); 2 CFR 200.112

Recordkeeping

  • High

    Maintain and submit SF-428 Tangible Personal Property Report if any equipment is purchased with grant funds, attached to interim and final reports.

    Deadline: If equipment purchased, report with each interim and final report submission

    Source: NPS Grant Reporting page; 2 CFR 200.313

  • HighOne Time

    Maintain and submit final property documentation including National Register nominations, easements, covenants, or preservation agreements per grant scope.

    Deadline: Submitted with final report as specified in grant agreement

    Source: NPS Grant Reporting page; grant agreement deliverables

Ongoing Eligibility

  • Clawback riskOngoing

    Ensure all preservation work, treatments, or designs conform to the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation.

    Deadline: Applies throughout project execution and submitted for approval before work proceeds

    Source: NPS National Historic Preservation Act page; 54 USC 306108, Section 106

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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 National Park Service.