Frequently asked questions about financial assistance

These are questions that recipients frequently ask concerning how to do business with NOAA. The questions and answers are divided into three categories: Pre-Award, Post-Award, and Policy.

Responses to Questions - Pre-Award:

What information classifies under the "OTHER" cost category?
- For the "OTHER" cost category, the recipient must provide details to any subaward information as well as costs related (but not limited) to printing, telephone, postage, rent, or training materials.
If fringe benefits are included with personnel costs - when is an explanation or detailed breakdown required?
- The budget narrative must include a detailed breakdown of fringe benefits (ie: FICA, life insurance, workers comp, etc.) only if the fringe rate applied is 35% or greater. If the fringe rate is 35% or greater, then the recipient must provide a description and breakdown of how the computation was done.
I have changed a dollar amount on the application (SF-424) and within the budget. Do I need to re-submit any revised documentation?
- If the dollar amounts changed after submitting the original application package, then a revised copy of the application package must be completed. This includes a signed and dated application (SF424), budget (SF424A), budget narrative, and potentially the project narrative which must be sent to the Grants Management Division (GMD) for review in order to maintain consistency and transparency across all required documents and the Grants Online system.
What is the difference between award eligibility criteria and award selection criteria?
- Award eligibility criteria refers to who or what entity is eligible to receive what federal assistance under a particular program. For example, a program may be restricted to non-profit applicants, Alaska Native Organizations, etc. Award selection criteria focuses on the merit of the application that is expressed in a reviewer's score which may include but is not limited to applicant capacity, how an applicant addresses program priorities as stated in the notice of funding opportunity (NOFO), and methodologies planned to implement activities. Either or both may be review-criteria applied during the funding process.
If I do not have an indirect cost rate agreement what do I do?
- Entities that have NEVER had an indirect cost rate agreement with the federal government can elect to use the de minimis rate of 10% of the modified total direct costs (MTDC) or apply for an indirect cost rate agreement with the Department of Commerce (as allowable under 2 C.F.R. §200.414).
How do I get a federally approved indirect cost rate from the Department of Commerce/NOAA?
- Is NOAA your organization's cognizant agency? The cognizant agency is the Federal agency with the largest dollar value of direct Federal awards provided to the organization requesting a Federally approved indirect cost rate. If NOAA is the cognizant agency, then an Indirect Cost Rate Proposal must be submitted to the NOAA Grants Management Division (GMD). The proposal is reviewed and analyzed by a CPA firm contracted by NOAA GMD for this specific purpose. After the review, an Indirect Cost Rate Agreement will be forwarded to the requesting organization's Authorized Representative for acceptance and countersignature.
How do you provide the detail for the sub-awards under the “other” line item?
- Please provide detail on the method of selection, purpose, and a separate budget narrative for each sub-award your organization is proposing within or attached to the budget narrative. Sub-award budget narratives may be part of the overall budget narrative or broken out individually.
Is the budget submitted with the application the official budget or an estimate?
- The SF-424A attached to the CD-450 when a new award is executed is considered the official budget. However, GMD knows that this budget is, for the recipient, an estimate. Thus the Uniform Guidance provides flexibility in the form of a 10% cumulative change threshold for requesting prior approval for rebudgeting. The official budget is the originally approved budget that you should compare your expenditures against in order to track changes up to the 10% cumulative threshold for rebudgeting. (Awards in which the Research Terms and Conditions apply should review the prior approval matrix.)
Can someone funded under a grant charge overtime, if applicable? This might mean that they are being paid more than 100% of salary.
- If the overtime charges are reasonable, necessary to the project, and in conformance with the recipient’s policies, then overtime may be paid with grant funds. In accordance with 2 CFR 200.430, staff members should not be paid for time not worked on the project (which constitutes over 100% of compensable time on the project).
Given the timeline for submissions and backlog at NICRA processing, many applicants submit NICRAs from the prior year. Is this OK?
- Grant applicants must submit their most recently approved NICRA as part of their application package. If the NICRA is expired, NOAA may reach out to inquire as to the status of an updated NICRA and/or may place a specific condition on the award requiring the recipient to submit the updated NICRA when it is received. However, for the purpose of the award, NOAA can accept the most recently approved rate.
Do we have to accept the sub-recipient’s indirect cost rate agreement, or can we impose ours?
- The recipient must accept a sub-recipient’s NICRA, as provided at 2 CFR 200.331 (a)(4). In the case that the sub-recipient does not have a NICRA, the sub-recipient may use the de minimus rate or negotiate a rate with the recipient.
If a grantee has submitted their documentation to request pre-award cost approval, but the documentation remains under review by GMD past the award start date, is the grantee allowed to start on the project? (with the understanding that they assume the risk if the award is not made)
- Prior approval for pre-award costs made up to, and including, 90 days before the award start date is waived by NOAA. In contrast, grant recipients must seek prior approval for reimbursement for pre-award costs over 90 days before the award start date. All costs incurred before NOAA gives the award are considered pre-award costs and are at the recipient’s risk. NOAA is under no obligation to reimburse pre-award costs if the recipient does not receive an award or the award is less than anticipated and inadequate to cover pre-award costs. Approval will be made in Grants Online by the Grants Office through the “Pre-Award Costs More than 90 Days” award action request.
What do you look for in the single audit to determine risks?
- NOAA reviews all audit findings to identify repeat audit findings, questioned costs, findings of material weakness or significant deficiencies. NOAA also reviews any corrective action plans to identify whether any findings have been addressed. Depending on the extent of the corrective action plan, NOAA may determine that the risk of non-compliance has been ameliorated, or that the risk of non-compliance is an ongoing issue.
If a sub-grantee does not spend over $750,000 in federal funds annually (which does not require a single audit), what risk assessment actions would be recommended?
- In accordance with 2 CFR 200.331, the pass through entity may evaluate risk based on the sub-recipient’s prior experience with similar awards, and verify performance in SAM and FAPIIS. A pass through entity may identify other risk assessment tools or procedures to implement, based on their experience.

Responses to Questions - Post-Award:

What procedure should be followed if a PI plans to leave an organization during the course of an active Federal award?
- If a PI plans to leave an organization during the course of an active Federal award, the organization has a right or privilege to nominate a replacement PI, request to sub-award to the original PI at the new organization, or transfer the grant to the PI's new organization. Replacement PIs are subject to NOAA approval. In cases where a particular PI's participation is integral to a given project and the PI's original and new organizations agree, an award transfer request shall be submitted. If the award is being transferred along with the PI leaving the initial recipient organization then the existing award must be terminated, funds must be deobligated, and a new award must be created which requires a new application from the new recipient organization.
Do I have to submit a SF424a with my rebudget request?
- Yes, it is mandatory that a revised budget (SF-424A) be submitted along with the rebudget award action request for the grants officer to review and approve the request. This will ensure exactly which amounts are being rebudgeted from a cost-category and into the other cost-category. On the SF-424A, specify the total approved budget for the award as well as the requested revisions and provide a detailed budget narrative explaining the transfer of funds.
What happens when the performance period/project ends?
- The "closeout" process begins by which the Federal awarding agency or pass-through entity determines that all applicable administrative actions and all required work for the Federal award has been completed.
What documents are required to closeout an expired award?
- The "closeout" process begins by which the Federal awarding agency or pass-through entity determines that all applicable administrative actions and all required work for the Federal award has been completed.
What happens if the project has expired but the work on the project has not been completed?
- The recipient can request a "no-cost extension" for non-research projects through the Grants Online System 30-days prior to the period of performance end date which will require prior approval from NOAA. For research projects, the recipient can grant themselves a one-time "no-cost extension" for up to 12 months without prior approval from NOAA.
  
  For the research projects/prior approval waived, the "no cost extension" must be submitted 10 days prior to the period of performance end date.
What is the difference between a Rebudget and a Change in Scope?
- A 10% threshold rebudget transfers funds between direct cost categories, which may be necessary to reflect variances in actual project costs. For research projects, recipients may rebudget between direct and indirects without prior approval. For research and non-research projects, any funds moved from participant support costs to other categories will require prior approval.
  
  A change in scope changes the direction, type of research or training, or other area of an award that constitutes a significant change from the aims, objectives, or purposes of the approved project.
  
  Actions likely to be considered a change in scope (therefore requiring Federal agency pre-approval) include, but are not limited to (1) change in the specific goals and objectives approved at the time of the award; (2) shift of the research emphasis; (3) change in the approved project areas or species; or (4) change in the amount of work from the approved project description (e.g., number of samples collected).
Where can I find policies regarding sexual assault and sexual harassment (SASH) related to contractors and financial assistance recipients?
- Policies regarding SASH related to contractors and financial assistance recipients can be found on the NOAA workplace harassment & training for contractors and financial assistance recipients page.
When does a sub-awardee have to submit a FFATA report?
- The primary recipient of the award is responsible for reporting FFATA information on their sub-awardees. The Federal Funding Accountability Act of 2006 allows the public to know which organizations are in receipt of federal dollars. The act requires information on federal awards to be posted on a singular, searchable, website (USAspending.gov). Per the DOC Financial Assistance Standard Terms and Conditions, “Under FFATA, recipients of financial assistance awards of $25,000 or more are required to report periodically on...subawards.”
Can there be multiple people with the same role in ASAP within an institution? (for example, the cash requestor role)
- Yes, multiple people can have the same role in ASAP.
Should recipients require supporting documentation with contractual services?
- Yes! All grant charges for goods/services acquired through a contract should be supported by adequate documentation, such as invoices, reports, and other documents showing the work that was completed. In addition, recipients should keep all contract competition documentation as records that the procurement standards at 2 CFR 200.317-326 were followed. Similar documentation should be kept on hand to document sub-award agreements.
To confirm, for research recipients, prior approval for rebudgeting is waived, while for non-research recipients, prior approval is required when creating a new line item on the SF-424A or making a cumulative 10% change between line items on the SF-424A.
- That is correct. However, all recipients (research and non-research) must obtain prior approval when transferring funds from participant support costs.
What happens when an organization receives a new rate agreement and the rate is higher than the rate submitted with the original application?
- The Uniform Guidance covers adjustments to NICRAs during and after a grant’s period of performance at 2 CFR 200.411. If a current recipient receives a new and higher rate that the originally submitted rate, the recipient may submit the NICRA to NOAA and submit a “rebudgeting” award action request.However, if an applicant chooses to voluntarily use a lower than approved rate at the beginning of the award, that rate must continue to be used.
Must a recipient use the NICRA that is in effect for each year of a multi-year agreement or can they opt to stick with the rate on the application as long as it is lower?
- A NICRA establishes the maximum amount of indirect costs that can be claimed under a federal award. An organization may opt to apply a rate that is less than the maximum allowed by their NICRA, but that cannot be a factor for evaluation during a competition. NICRAs are designed to reimburse organizations for the actual costs expended on indirect costs across the organization, so the situation in which an organization opts to charge less than their NICRA establishes, should be rare. In general, a recipient should charge the applicable rate for each year of their grant.
Our indirect cost rate agreement changes every year, what should I do when the award has already been accepted and realize the wrong rate was used for the budget?
- The Uniform Guidance covers adjustments to NICRAs during and after a grant’s period of performance at 2 CFR 200.411. If the award is current, the recipient may submit a new NICRA and any budget revisions using the “rebudgeting” award action request. If the award has closed and the new rate would create a refund for NOAA, checks can be submitted to NOAA Finance at:
  - NOAA Office of Finance
    U.S. Department of Commerce
    20020 Century Blvd
    Building CXXI, SOU2141, Room 2304
    Germantown MD 20874-1143
Our rate agreement exempts sub-recipient contracts, but not vendor contracts. What should I do if I miscategorized a sub-recipient as a vendor?
- If you realize that you have made an honest mistake in applying the rate authorized by your NICRA, you may submit a “rebudgeting” award action request to revise the budget (if the award is open), or, if the mistake is realized after the award is closed and a refund is due to NOAA, checks can be submitted to NOAA Finance (see above address).
My organization receives grant funding from the Global Environment Facility (GEF), which is a grantmaking organization that many countries (including the US government), contribute to. My question is whether my organization can count expenditures that are funded by the GEF as non-federal matching funds for a NOAA award? Since the US government is a contributor to the GEF fund, along with many other countries, are those funds considered federal or non-federal funds?
- Matched funding must be contributed from non-federal sources. In this situation, if your organization is able to identify the percentage of funds contributed by the US government to the GEF and make a proportionate exclusion of these funds from being considered as match on a NOAA award, the remainder may be considered match funding that is non-federal in source. This is a difficult undertaking, so we would advise that you keep verifiable documentation in your organizational files to track this process.
Can international funds be used as match?
- Match funding must be non-federal in source. International funds not originating from the U.S. government may be considered match funding.
Can grantees request extensions for the submission of their progress or financial reports? If so, how?
- No, there is no action in Grants Online that will permit a recipient to request an extension for a progress or financial report. A recipient may alert NOAA that a report will be late and provide a justification, but Grants Online will continue to consider the report to be delinquent and send auto-notifications that a report is delinquent.
If a sub-recipient purchases a piece of equipment under their sub-award, when the award is complete, who should take ownership?
- The terms and conditions of the federal award flow downwards to all subrecipients (sub-grantees). The award recipient (non-federal entity) is responsible for the oversight of their subrecipients. Sub-recipients that purchased equipment with federal funds must follow the disposition instructions at 2 CFR 200.313, reporting to the award recipient (non-federal entity). The award recipient (non-federal entity) is then responsible for requesting disposition instructions from NOAA (if applicable).
Who is responsible for approving sub-recipient purchases of equipment?
- The award recipient (non-federal entity) is responsible for approving sub-recipient purchases of equipment.
What is the appropriate documentation to provide when an awardee has to take an upgraded seat assignment on a flight?
- All costs using federal funds must be reasonable, allowable, allocable, and necessary to the project. If an upgraded seat assignment is given to a recipient staff member at no additional cost, the originally purchased seat assignment documentation may be used.

Responses to Questions - Policy:

How many days should the Notice of Funding Opportunity (NOFO) be posted to Grants.gov?
- In accordance with the uniform guidance (2 CFR Part 200), the NOFO must generally be available for applications for at least 60 days, but no less than 30 days. Any NOFO's under 30 days are only for exigent and unique circumstances. The Grants Management Division requires approval from its Director, delegated by the Federal Awarding Agency head, for only competitive NOFO's under 60 days to assure a minimum timeframe useful to applicants.
We would like to start work on the project, however an official offer of award has not been made. Could we be reimbursed for such expenses prior to the official signature (including if financial assistance is not awarded)?
- The Grant Officer's signature and offer of financial assistance award via the CD-450 award document is the official offer of an award. If a grant or cooperative agreement is not awarded, there is no obligation on the part of the Federal government to reimburse any expenses.
  
  In the case that an award is offered and accepted, recipients should reference §200.458 Pre-award costs, which states that "Pre-award costs are those incurred prior to the effective date of the Federal award directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency." For research awards, see the prior approval matrix in the Research Terms and Conditions regarding the waiver of prior approval for pre-award costs in certain circumstances. Click here to view the main page for the Research Terms & Conditions.
If I will be interviewing participants or hosting focus groups with members of the public, will I need approval from an Institutional Review Board (IRB)?
- Yes - after the application has been selected by the Agency for funding, the recipient that was selected must submit the project for review by the recipient's Institutional Review Board (IRB) for approval. Approval documentation from the IRB can be submitted to the Federal Program Officer or the Grants Management Specialist assigned to the award before the Project Start Date electronically to ensure compliance with this requirement. Federal funding cannot be expended on the project until the Agency receives IRB approval documentation.
Can a Federal Employee work on a project funded by the Agency?
- Yes - however, any expenses that will be incurred by the Federal Employee working on the Federally-funded project must be conducted by a transfer of funds between Agencies (outside of the grant/cooperative agreement). When submitting a new application, it is important to note that expenses for the Federal Employee will not be paid through the Federal award.
What is a multi-year vs. multiple year?
- A multi year award is an award that is 2 years or longer and the funds are distributed over the life of the award. A multiple year award is an award 2 years or longer but the entire amount of the funds is given in the first year.
Can federal funds be used for subawards on an award?
- Yes, federal funds can be used for subawards.
What is the difference between a contract, a grant, and a cooperative agreement?
- The law states that Contracts are awarded when a Federal agency is acquiring something – a service, for example. Both grants and cooperative agreements are awarded when a Federal agency is providing assistance – the latter involving a greater degree of participation and oversight by the agency. The Federal Grant and Cooperative Agreement Act set out to guide government agencies in their use of Federal funds – particularly by distinguishing between contracts, cooperative agreements and grants. Read the full text of the Federal Grant and Cooperative Agreement Act (1977).
I have a project spanning more than a year. Is an annual breakdown of the budget required?
- The annual breakdown of the budget is required regardless of the dollar amount and timeframe of the project. This is also applicable for multi-year and multiple year awards.
Can federal employees travel be charged for a site visit using awarded federal funds?
- No, the Program Office should have a budget separate for the individual program that includes travel for management and oversight.
What happens if there is an indirect rate change during the project period?
- Once a new rate is approved, with an effective period of the agreement, your organization must submit a new indirect cost rate agreement (also known as a negotiated indirect cost rate agreement (NICRA)) to NOAA and you may submit a re-budget request (if necessary). If the actual new approved indirect rate chargeable to the award is less than the original rate used under the award, you may submit a re-budget request to use the difference to direct costs under the award. In addition, you may elect to charge less than the full amount of allowable indirect costs to the award in order to pay for additional allowable direct costs.
If the Uniform Guidance, DOC Financial Assistance Standard Terms and Conditions, and NOAA Financial Assistance Administrative Terms are in conflict concerning an issue--for example, reporting requirements--what should a grant recipient do?
- There should be no conflicts between the terms and conditions that apply to your award. If you find a conflict, please bring it to the attention of your Grant Management Specialist or Grant Officer.
What conditions need to be passed on to contractors? (only those listed in Appendix II of the Uniform Guidance)?
- The conditions listed in Appendix II of the Uniform Guidance are required to be included in contracts. 2 CFR 200.101 has a table showing which portions of the Uniform Guidance apply to contractors. The recipient may also impose additional terms and conditions as necessary to ensure the success of the contract (ie, reporting, invoice requirements, acceptable quality levels, record keeping requirements, etc.).
  
  Please note that per 2 CFR 200.101, all the terms and conditions that apply to the federal grant agreement also apply to any subgrants. Consult the NOAA Terms and Conditions for specific instructions on reporting, scientific integrity Subgrantees with an award under the research terms and conditions should consult the Research Terms and Conditions Appendix B, Subaward Requirements to identify the terms and conditions applicable by subrecipient organization type.
If the sub-recipient does not comply with the specific terms and conditions of the award or does not provide adequate documentation for the invoice, what is the prime recipient’s responsibility to resolve the issue? Can the prime recipient deny payment? Can the prime revoke the contract? Does the prime recipient notify NOAA?
- The recipient of the award is responsible for monitoring any sub-recipients. NOAA has no direct legal relationship with sub-recipients of awards and cannot interfere between the recipient and sub-recipient. NOAA would like to be kept informed of any sub-recipient issues, as the project could be delayed as a result. The recipient may take the actions identified at 2 CFR 200.338, or any other provisions identified in the sub-award agreement.
What are some of the differences in monitoring & risk assessment approaches between a subgrant and a subcontract?
- The differences in monitoring and risk assessment approaches between a sub-grant and a subcontract stem from the fact that all of the terms and conditions of the federal award flow downwards to a sub-grant, but only the terms and conditions required in Appendix II of the Uniform Guidance and any terms and conditions written into the contract apply to subcontracts. For example, sub-grantees are required to abide by the single audit requirements, while subcontractors are not. Pass through entities are required to review financial and performance reports for their subgrantees, per 2 CFR 200.331, but the Uniform Guidance does not provide a similar requirement for subcontracts. Your organization should have policies on monitoring and risk evaluation for both subcontracts and subgrants.
What are some types of sub-recipient monitoring?
- Sub-award monitoring practices are identified at 2 CFR 200.331 (b). This includes reviewing financial and performance reports, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies detected through audits, on-site reviews, and other means; issuing a management decision for audit findings, etc.

Frequently asked questions about financial assistance

Questions - Pre-Award:

Questions - Post-Award:

Questions - Policy:

Responses to Questions - Pre-Award:

What information classifies under the "OTHER" cost category?

If fringe benefits are included with personnel costs - when is an explanation or detailed breakdown required?

I have changed a dollar amount on the application (SF-424) and within the budget. Do I need to re-submit any revised documentation?

What is the difference between award eligibility criteria and award selection criteria?

If I do not have an indirect cost rate agreement what do I do?

How do I get a federally approved indirect cost rate from the Department of Commerce/NOAA?

How do you provide the detail for the sub-awards under the “other” line item?

Is the budget submitted with the application the official budget or an estimate?

Can someone funded under a grant charge overtime, if applicable? This might mean that they are being paid more than 100% of salary.

Given the timeline for submissions and backlog at NICRA processing, many applicants submit NICRAs from the prior year. Is this OK?

Do we have to accept the sub-recipient’s indirect cost rate agreement, or can we impose ours?

If a grantee has submitted their documentation to request pre-award cost approval, but the documentation remains under review by GMD past the award start date, is the grantee allowed to start on the project? (with the understanding that they assume the risk if the award is not made)

What do you look for in the single audit to determine risks?

If a sub-grantee does not spend over $750,000 in federal funds annually (which does not require a single audit), what risk assessment actions would be recommended?

Responses to Questions - Post-Award:

What procedure should be followed if a PI plans to leave an organization during the course of an active Federal award?

Do I have to submit a SF424a with my rebudget request?

What happens when the performance period/project ends?

What documents are required to closeout an expired award?

What happens if the project has expired but the work on the project has not been completed?

What is the difference between a Rebudget and a Change in Scope?

Where can I find policies regarding sexual assault and sexual harassment (SASH) related to contractors and financial assistance recipients?

When does a sub-awardee have to submit a FFATA report?

Can there be multiple people with the same role in ASAP within an institution? (for example, the cash requestor role)

Should recipients require supporting documentation with contractual services?

To confirm, for research recipients, prior approval for rebudgeting is waived, while for non-research recipients, prior approval is required when creating a new line item on the SF-424A or making a cumulative 10% change between line items on the SF-424A.

What happens when an organization receives a new rate agreement and the rate is higher than the rate submitted with the original application?

Must a recipient use the NICRA that is in effect for each year of a multi-year agreement or can they opt to stick with the rate on the application as long as it is lower?

Our indirect cost rate agreement changes every year, what should I do when the award has already been accepted and realize the wrong rate was used for the budget?

Our rate agreement exempts sub-recipient contracts, but not vendor contracts. What should I do if I miscategorized a sub-recipient as a vendor?

Can international funds be used as match?

Can grantees request extensions for the submission of their progress or financial reports? If so, how?

If a sub-recipient purchases a piece of equipment under their sub-award, when the award is complete, who should take ownership?

Who is responsible for approving sub-recipient purchases of equipment?

What is the appropriate documentation to provide when an awardee has to take an upgraded seat assignment on a flight?

Responses to Questions - Policy:

How many days should the Notice of Funding Opportunity (NOFO) be posted to Grants.gov?

We would like to start work on the project, however an official offer of award has not been made. Could we be reimbursed for such expenses prior to the official signature (including if financial assistance is not awarded)?

If I will be interviewing participants or hosting focus groups with members of the public, will I need approval from an Institutional Review Board (IRB)?

Can a Federal Employee work on a project funded by the Agency?

What is a multi-year vs. multiple year?

Can federal funds be used for subawards on an award?

What is the difference between a contract, a grant, and a cooperative agreement?

I have a project spanning more than a year. Is an annual breakdown of the budget required?

Can federal employees travel be charged for a site visit using awarded federal funds?

What happens if there is an indirect rate change during the project period?

If the Uniform Guidance, DOC Financial Assistance Standard Terms and Conditions, and NOAA Financial Assistance Administrative Terms are in conflict concerning an issue--for example, reporting requirements--what should a grant recipient do?

What conditions need to be passed on to contractors? (only those listed in Appendix II of the Uniform Guidance)?

What are some of the differences in monitoring & risk assessment approaches between a subgrant and a subcontract?

What are some types of sub-recipient monitoring?