POST-AWARD COMPLIANCE CHECKLIST

USDA Community Facilities Grant & Loan: Compliance Requirements

What you must do after you win this award — administered by US Department of Agriculture · Federal Program.

8
Total requirements
3
Clawback-risk items
8
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Premature or improper disbursement can trigger clawback and disallowed costs
  • Environmental: Failure to complete environmental review can halt project and trigger cost disallowance
  • Labor & Wage: Discrimination violations can result in grant suspension, termination, and cost recovery
  • Recordkeeping: Lack of supporting documentation renders costs ineligible for reimbursement
  • Procurement & Vendor Rules: Unapproved procurement or construction can result in disallowed costs and project delays
  • Financial & Cost Eligibility: Unauthorized use or disposition of property can trigger clawback of grant funds
  • Financial & Cost Eligibility: Non-compliant procurement can trigger cost disallowance and grant modification
  • Reporting: Failure to report can result in suspension of future funding and compliance violations

Reporting

  • MediumSemi Annual

    Awardees must report information about sub-awards and executive compensation in accordance with 2 CFR part 170 (Federal Funding Accountability and Transparency Act).

    Deadline: By established FFATA reporting deadlines

    Source: 2 CFR part 170; 2 CFR part 25

Financial & Cost Eligibility

  • Clawback riskEvent Driven

    Grant funds will not be disbursed until they are actually needed and all borrower or other non-federal funds are expended first, except when interim financing is arranged.

    Deadline: At each disbursement request

    Source: 7 CFR 3570.68(d)

  • HighOne Time

    Property acquired or improved with grant funds may be subject to use and disposition conditions, and liens or other notices may be required per 2 CFR 200 as adopted by USDA.

    Deadline: At time of property acquisition/improvement

    Source: 7 CFR 3570.68(c); 2 CFR 200.311-316

  • HighOngoing

    Awardees must comply with Build America, Buy America (BABAA) requirements, ensuring that iron, steel, and manufactured goods used in the project meet domestic content standards.

    Deadline: At time of procurement and throughout construction

    Source: 2 CFR 200; Section 70914 of BABAA (Pub. L. 117-58)

Procurement & Vendor Rules

  • HighEvent Driven

    All construction contracts, bids, and procurement must follow RD-approved plans and specifications with RD concurrence on construction contract documents and ongoing construction monitoring.

    Deadline: Contracts must be approved before execution; monitoring ongoing during construction

    Source: 7 CFR 3570.68(b); RD State Architect approval requirements

Labor & Wage

  • Clawback riskOngoing

    Awardees must comply with all applicable civil rights laws including Title VI, Section 504, Age Discrimination Act, Title VIII, Title IX, and Equal Credit Opportunity Act.

    Deadline: Throughout project implementation and facility operation

    Source: 7 CFR 3570; 2 CFR 200.330

Environmental

  • Clawback riskOne Time

    Awardees must comply with National Environmental Policy Act (NEPA) requirements and submit environmental findings for USDA review per 7 CFR 1970.

    Deadline: Prior to project approval and before construction begins

    Source: 7 CFR 3570; RD Instruction 1970

Recordkeeping

  • HighOngoing

    Awardees must maintain records to document all activities and expenditures using grant funds and matching funds in accordance with 2 CFR 200 as adopted by USDA.

    Deadline: Throughout grant term and retention period per 2 CFR 200.333

    Source: 7 CFR 3570; 2 CFR 200 (adopted by USDA through 2 CFR 400)

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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 Department of Agriculture.