POST-AWARD COMPLIANCE CHECKLIST

Ohio Historic Preservation Tax Credit: Compliance Requirements

What you must do after you win this award — administered by Ohio History Connection · Ohio.

9
Total requirements
6
Clawback-risk items
9
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Reporting: Failure to submit certification timely may result in denial of tax credit issuance and loss of the awarded credit amount.
  • Financial & Cost Eligibility: Undocumented, unsupported, or ineligible costs will be disallowed and reduce the tax credit amount or result in recapture of issued credits.
  • Environmental: Work that violates the Standards may be deemed ineligible for the tax credit; costs associated with non-compliant work will be disallowed.
  • Financial & Cost Eligibility: If applicant incurs more than 25% of QREs prior to Part 2 approval, all costs incurred prior to approval are ineligible, reducing or eliminating the tax credit.
  • Ongoing Eligibility: Any QREs incurred before Part 2 approval are completely disallowed and excluded from the tax credit calculation, resulting in reduced award amount.
  • Reporting: Non-compliance identified in Part 3 review will result in partial or complete denial of the tax credit and potential recapture of advance allocations.
  • Recordkeeping: Failure to maintain or provide records upon request may result in partial or complete disallowance of claimed QREs and recapture of tax credits.
  • Other Obligations: Violations of this requirement may result in rescission of the tax credit award and recapture of any issued credits.
  • Reporting: Failure to provide requested status reports may result in withholding of tax credit issuance or clawback of awarded credits.

Reporting

  • Clawback riskOne Time

    Applicants must submit the Request for Certification and Notice of Project Completion form within 90 days of completing the project to initiate the tax credit issuance process.

    Deadline: Within 90 days of project completion

    Source: OHPTC Program Guidelines; OHPTC FAQ (2024)

  • Clawback riskOne Time

    Upon project completion, SHPO must review Part 3 (final certification application) documentation to confirm that completed work complies with the Secretary of the Interior's Standards and matches the approved Part 2 scope.

    Deadline: As part of certification process following project completion

    Source: OHPTC Program Policies; SHPO review procedures

  • MediumEvent Driven

    Status reports on project progress must be submitted if requested by the Ohio Department of Development, not to exceed twice per year. Reports must include updates on project status, expenditures, and compliance.

    Deadline: Within timeline specified by Development request; not more than twice per year

    Source: OHPTC Program Policies p.17 (Monitoring and Reporting)

Financial & Cost Eligibility

  • Clawback riskOngoing

    All Qualified Rehabilitation Expenditures must be fully documented with invoices, receipts, and evidence of payment. Records must demonstrate costs were incurred and paid in accordance with the approved project scope.

    Deadline: Throughout project execution; must be available for certification submission

    Source: OHPTC Program Policies §Recordkeeping, ORC 149.311

  • Clawback riskOne Time

    At the time of application, applicants must demonstrate that no more than 25 percent of total Qualified Rehabilitation Expenditures have been incurred. Applicants must commit in writing to expend the remaining 75 percent after approval.

    Deadline: At application submission; ongoing compliance through project completion

    Source: OHPTC Round 10 Application; OHPTC FAQ; ORC 149.311

Environmental

  • Clawback riskOngoing

    Rehabilitation work must comply with the Secretary of the Interior's Standards for Rehabilitation (36 CFR 67). Non-compliance may be identified during SHPO/NPS Part 3 review of completed work.

    Deadline: Prior to and during project completion; verified at Part 3 certification review

    Source: 36 CFR 67; OHPTC Program Policies; ORC 149.311(C)(2)

Recordkeeping

  • HighOngoing

    Applicants must maintain comprehensive records documenting project expenditures, compliance with the Secretary of Interior's Standards for Rehabilitation, and all supporting documentation. Records must be available for state review.

    Deadline: Throughout project and retained for audit period

    Source: OHPTC Program Policies p.15-17 (Monitoring and Reporting); ORC 149.311(B)(5)

Ongoing Eligibility

  • Clawback riskOne Time

    Work performed prior to receiving a positive recommendation on the applicable Part 2 Historic Preservation Certification Application will not be eligible for the tax credit calculation, even if later approved.

    Deadline: Must wait for Part 2 approval before commencing substantial rehabilitation work

    Source: OHPTC Round 10 Application Attachment B

Other Obligations

  • HighOngoing

    Tax credit recipients must not have undertaken work to adjacent historic buildings that violates the Secretary of the Interior's Standards if done to benefit the credited project. Such violations may render the project ineligible.

    Deadline: Throughout project execution and scope

    Source: OHPTC Program Policies p.9

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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 Ohio History Connection.