Ohio Brownfield Remediation Program: Compliance Requirements

Grantees must submit project deliverable documentation before grant closeout. Development may request additional documentation as reasonably necessary to demonstrate project completion.

Deadline: Due at grant closeout; specific deadline determined by grant agreement

Source: Ohio BRP FY25 FAQ (questions 39-40)

Grantees must not exceed 10% of the total grant request amount for administrative costs. Administrative costs are limited to reimbursement requests, reporting information submission, and professional fees as defined by uniform cost guidance.

Deadline: Must comply throughout the grant period; all administrative costs subject to post-award review

Source: Ohio BRP Program Guidelines / 2 CFR 200 Uniform Guidance (referenced in program materials)

Grantee must comply with match requirements: no match required for county set-aside funding ($1 million per county), but 25% local match required for competitive grants awarded outside county allocation.

Deadline: Match commitment must be documented in grant application; costs must be incurred or documented by project closeout

Source: Ohio Brownfield Remediation Program Guidelines; House Bill 96

Costs incurred prior to the date of grant award are not reimbursable. However, costs incurred in the two years prior to grant award are eligible to count as matching funds if properly documented.

Deadline: Reimbursement requests must clearly identify pre-award vs. post-award costs; match documentation must reference dates of incurrence

Source: Ohio BRP Guidelines; Environmental Law Blog citing program requirements

Grantees must comply with Ohio prevailing wage law (ORC 4115.03-4115.16) for all mechanics and laborers employed in construction work financed with grant funds.

Deadline: Applies to all construction activities funded with grant proceeds; must consult Ohio Department of Commerce Bureau of Wage and Hour Administration for wage determinations

Source: Ohio Brownfield Remediation Program Guidelines; ORC 4115.03-4115.16

For VAP-eligible sites, grantee must pursue a Covenant Not-to-Sue (CNS) in addition to a No Further Action (NFA) Letter; Development prefers CNS completion. VAP-ineligible sites need not pursue VAP documentation.

Deadline: CNS must be obtained before project closeout for VAP-eligible sites; CNS professional fees are eligible grant expenses

Source: Ohio BRP FY25 FAQ (question 37)

Grantees must maintain verified and signed timesheets documenting administrative costs, including hourly pay rates, number of hours billed, employee names, dates costs were incurred, and type of work performed.

Deadline: Records must be maintained during grant performance and available for audit; required for all reimbursement requests

Source: Ohio BRP FY25 FAQ (2.14.25); uniform cost guidance referenced

Grantee must maintain compliance with grant agreement terms. Director of Development may terminate the agreement and demand repayment of all or part of disbursed grant funds if grantee is found non-compliant.

Deadline: Compliance is a continuous obligation; non-compliance can be identified at any time during award period

Source: Ohio Administrative Code Rule 122:31-1-05(B) and (C)

Grantee must request and receive written approval from Ohio Department of Development before making any changes to an approved brownfield remediation program project.

Deadline: Written approval must be obtained prior to implementing any project changes; no retroactive approval permitted

Source: Ohio Administrative Code Rule 122:31-1-05(C)