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Summary: Subpart C governs the "due diligence" phase of the grant, detailing how federal agencies must vet applicants and how awards must be structured for maximum transparency. It mandates a "Risk Assessment" for every applicant, looking at past performance, financial stability, and the quality of management systems. This subpart ensures that the "Notice of Funding Opportunity" (NOFO) clearly communicates all requirements, so applicants aren't surprised by compliance burdens later. It also sets the standards for the "Federal Award Identification" (FAIN) and other data points that must be included in the grant agreement. For a municipality, this subpart is a checklist for "grant readiness," ensuring their systems are robust enough to attract federal investment. It emphasizes the importance of transparency in the selection process, whether competitive or formula-based. Ultimately, Subpart C ensures that federal funds are only awarded to entities with a demonstrated capacity for "Fiscal Resiliency."
● §200.201 Use of Grant Agreements: You must distinguish between "Fixed Amount" awards and "Cost Reimbursement" awards to set up your accounting correctly. This is essential because the reporting and "allowability" rules differ significantly between the two.
● §200.202 Program Planning and Design: You must ensure your project goals are clearly defined and measurable before applying. This is essential because federal agencies now focus on "Performance-Based" outcomes rather than just spending.
● §200.203 Requirement to Provide Public Notice: You must monitor the official federal "Notice of Funding Opportunity" to ensure your application meets all deadlines and criteria. This is essential to prevent administrative disqualification of a high-priority project.
● §200.204 Notices of Funding Opportunities: You must analyze the NOFO to identify specific "Cost Sharing" or "Matching" requirements. This is essential for local budget planning to ensure the municipality can meet its financial obligations.
● §200.205 Federal Awarding Agency Review of Merit: You must draft applications that speak directly to the technical evaluation criteria listed in the NOFO. This is essential for securing funding in a highly competitive environment for limited federal dollars.
● §200.206 Federal Awarding Agency Review of Risk: You must maintain updated "Single Audits" and financial statements to demonstrate you are a "Low-Risk" applicant. This is essential because a high-risk rating leads to intrusive monitoring and restrictive payment terms.
● §200.207 Standard and Specific Conditions: You must review your award document for "Specific Conditions" that may have been added due to your risk profile. This is essential to ensure you are meeting the additional hurdles required to keep your funding active.
● §200.208 Certifications and Representations: You must have an authorized official sign all required federal certifications. This is essential as it legally binds the municipality to the terms of the grant and carries "False Claims Act" penalties.
● §200.209 Pre-Award Costs: You must seek written approval before spending money on a project before the grant is officially awarded. This is essential to prevent "unallowable" costs that will not be reimbursed by the federal agency.
● §200.210 Information Contained in a Federal Award: You must extract and file the "FAIN" and "CFDA" numbers for your financial system. This is essential for accurate "Schedule of Expenditures of Federal Awards" (SEFA) reporting.
● §200.211 Public Access to Federal Award Information: You must be aware that your award details will be public on USAspending.gov. This is essential for maintaining public trust and ensuring "Fiscal Resiliency" is visible to the community.
● §200.212 Reporting a Determination of Non-Responsibility: You must maintain compliance to avoid being listed in the "SAM.gov" database as non-responsible. This is essential because such a listing can bar the municipality from all federal funding for years.
● §200.213 Suspension and Debarment: You must check "SAM.gov" to ensure your contractors are not debarred from federal work. This is essential as paying a debarred contractor is a "strict liability" violation that leads to immediate de-obligation.