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OMB control number 2030-0020
EPA ADMINISTRATIVE AND FINANCIAL
ONSITE REVIEW QUESTIONNAIRE
I. Organization Policies and Procedures
A. General Information / Policies and Procedures. Many of
these questions have “Yes” or “No” answers.
For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain
all “No” and “Not Applicable” answers.
Thank you in advance for completing this questionnaire.
Note: 40 CFR 30 and OMB Circular A-122 (now codified as 2 CFR Part
230) references apply to Non Profits, Hospitals and Educational
Institutions. 40 CFR 31 and OMB Circular A-87 (codified as 2 CFR 225)
references apply to States, Local Governments and Indian Tribes. OMB
Circular A-21 (codified as 2 CFR 220) references apply to Educational
Institutions.
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Who or which office(s) in your
organization is/are responsible for reviewing, approving and
signing applications, awards and amendments?
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Who or which office(s) in
your organization is/are responsible for monitoring and
overseeing assistance agreements once received from EPA?
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3. Do you have a current Organizational Chart? Show or
explain any non profit or for profit organization and/or entities
your affiliated with.
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4. How does your organization keep up-to-date on federal
regulations, legal decisions, OMB Circulars, etc.?
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5. Does your organization have provisions for seeking
written prior approvals for specific revisions, from the awarding
agency under certain conditions? (40 CFR 30.25
(c), 40 CFR 31.30)
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EPA form number 6600-01
The Code of Federal Regulations (40), and OMB Circulars require
organizations receiving federal assistance agreements to have
written policies and procedures for the following areas. (40 CFR
30.21 and 30.22, 40 CFR 31.20 and 31.21) Do your policies and
procedures address the items described below?
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Personnel, including qualifications for each position,
duties and responsibilities, salary ranges, EEO, annual
performance appraisals, types and levels of fringe benefits,
and standards of conduct governing duties and responsibilities
including disciplinary actions for not adhering to the
standards, for employees engaged in the award and
administration of contracts. (OMB A-122 / 2 CFR
Part 230, Appendix B, paragraph 8 and 40 CFR 30.42; OMB A 87 /
2 CFR Part 225, Appendix B, section 8 and 40 CFR 31.36 (b)(3);
OMB A 21 / 2CFR Part 220, Appendix A, section J.10.)
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b. Time reporting, tracked to each
project; (OMB A 122 /2 CFR Part 230, Appendix B,
paragraph 8.m; OMB A 87 / 2 CFR Part 225, Appendix B, Section
8.h; OMB A-21 / 2 CFR Part 220, Appendix A, section J.10 )
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Redistributions (Chargeback’s); (i.e., other
organizational department costs; written, established rates
required)
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d. Payroll processing and internal controls; (OMB
A 122 /2CFR Part 230, Appendix B, paragraph 8.m; OMB A 87 / 2CFR
Part 225, Appendix B, Section 8.h; OMB A-21/ 2 CFR Part 220,
Appendix A, section J.10)
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e. Overtime (if allowed); (OMB A-122 / 2CFR
Part 230, Appendix B, paragraph 8.f; OMB A-87 / 2CFR Part 225,
Appendix B, section 8;
OMB A-21 / 2 CFR 220,
Appendix A, section J.10)
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Vacation and Sick Leave (if offered by your
organization); (OMB
A 122 / 2 CFR Part 230,
Appendix B, paragraph 8 g; OMB A 87 / 2 CFR
Part 225,
Appendix B, section 8.d; OMB A-21 / 2 CFR 220, Appendix A,
Section J.10(f))
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g. Compensatory time (if allowed). (OMB A
122 / 2 CFR Part 230, Appendix B, paragraph 8.d)
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EPA form number 6600-01
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h. Equipment and property purchases including cost and
price analysis, purchase, use of, inventory and disposition of at
the end of the project; (40 CFR 30.34 and 30.44,
40 CFR 31.31, 31.32 & 31.36(f))
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(A cost analysis is the review and evaluation of each element of cost
to determine reasonableness, allocability and allowability when you
do not have other proposals to compare costs against. A price
analysis may be accomplished in various ways, including the
comparison of price quotations submitted, market prices and similar
indicators, together with discounts)
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i. Electronic Funds Transfers (EFT) drawdowns from EPA’s
accounts. Does your policy address who is authorized to request
payment from the federal government, what procedures are used to
verify that the request are accurate, and when drawdown of funds
will occur etc.; (40 CFR 30.21 (b)(5) and 30.22,
40 CFR 31.20(b)(7) and 31.21)
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j. Receipt and deposit of advanced payments (40
CFR 30.22(i)(2) and 40 CFR 31.21(c)&(e))
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k. Records retention. (40 CFR 30.50 and
30.53, 40 CFR 31.42)
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l. Travel, authorizations, vouchering after the trip and,
if required, trip reporting; (OMB A 122 / 2CFR
Part 230, Appendix B, paragraph 51;
OMB A 87 / 2CFR Part
225, Appendix B, section 43; OMB A-21 / 2 CFR 220, Appendix A,
section J 53)
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m. Procurement Standards for
supplies, expendable property, equipment, real property and
services. Standards for contracting,
purchasing, consultant
agreements, sub-awards or grants (if applicable, especially for
monitoring sub grantees) and other types of awards that transfer
federal funds outside of your organization; (40
CFR 30.40 through 30.47, 40 CFR 30.5 & 30.51(a), 40 CFR
31.36, 40 CFR 31.37 and 31.40(a))
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n. Provisions for utilizing Small Businesses, Minority
Owned Firms, Women’s Business Enterprises, and Labor
Surplus Area Firms
(where possible) (40 CFR
30.44(b), 40 CFR 31.36(e))
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EPA form number 6600-01
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o. Program income. Is it identified, authorized, accounted
for, and are limitations placed on its use; (40
CFR 30.24, 40 CFR 31.25)
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p. Cost sharing, matching and In-Kind contributions. Is
it identified, accounted for and reported; (40 CFR
30.23 and OMB A 122 / 2CFR Part 230, Appendix B, paragraph 12; 40
CFR 31.24 and OMB A 87 / 2CFR Part 225, Appendix B, section 12;
OMB A-21 / 2 CFR 220, Appendix A, Section J.15(b))
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7. Do you have the following documents for each grant award:
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a. Original application and certifications; (SF 424, 424A,
et al.)
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b. Work plans and/or statement of work;
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c. Initial award and all amendment documents;
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d. Request for and approvals of scope and/or budget
changes; (40 CFR 30.25 (b)&(c), 40 CFR 31.30
(a),(b) & (c)).
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e. Financial Status Reports and reimbursement requests, if
applicable; (40 CFR 30.52 (a)(1), 40 CFR 31.41(b))
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f. Payment requests backed up by financial records to
support the request; (40 CFR 30.21(a) and
30.21(b)(2), 40 CFR 31.20(a)(2))
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g. Progress reports; (40 CFR 30.51 (b), 40
CFR 31.40(b))
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EPA form number 6600-01
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h. Contracts / Subgrants; (40 CFR 30.46 and
30.47 and 40 CFR 31.37)
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i. Purchases; (40 CFR 30.34 or 40 CFR 31.32
for equipment, 40 CFR 30.35 or 40 CFR 31.33 for supplies)
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j. Consultant agreements; (40 CFR 30.27 (b)
or 31.36(j))
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k. Correspondence and approvals, including emails to and
from EPA officials.
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II. Accounting
and Financial Management
Many of these questions have “Yes” or “No”
answers. For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
Accounting
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1. Does your organization have an accounting manual? (40
CFR 30.21 (b) (5) & (6) or 40 CFR 31.20) The CFR
requires certain accounting practices / procedures addressed in
the questions below to be written.
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2. Does your organization’s accounting and
financial management system(s) follow Generally Accepted
Accounting Principles (GAAP)? (OMB Circular A-122
/2CFR Part 230, Appendix A, paragraph A.2.e; OMB A 87 / 2CFR Part
225, Appendix B, section 8, OMB Circular A 21 / 2 CFR 220,
Appendix A, section J)
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3. Does your organization’s accounting and financial
management system(s) provide accurate, current and complete
disclosure of the financial results of each federally-sponsored
project or program (i.e. each award is accounted for separately)
(40 CFR 30.21 (b)(1) or 31.20(b)(1)), and
produce financial reports in accordance with the requirements of
40 CFR 30.52 or 40 CFR 31.41?
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EPA form number 6600-01
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4. Does your organization’s financial management
system(s) provide records that adequately identify the source and
application of funds for federally-sponsored activities, such as
authorizations, obligations, unliquidated obligations, assets,
outlays, income and interest? (40 CFR 30.21 &
30.22; 40 CFR 31.20,.21,&.22)
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5. Does your organization’s financial management
system(s) provide effective control over, and accountability for
all funds, property and other assets, including ensuring that all
such assets are used solely for purposes authorized by the
awards? (40 CFR 30.21 (b)(3); 40 CFR 31.20(b)(3)).
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6. Does your
organization have written policies and procedures to ensure that
costs are reasonable, allocable and allowable? 40
CFR 30.21 (b)(6); 40 CFR 31.20(b)(5); OMB Circular A-122 / 2CFR
Part 230, Appendix A, Section A, OMB Circular A-87 / 2CFR Part
225, Appendix A, Section C; OMB Circular A 21 / 2 CFR 220,
Appendix A,, Section C)
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7. Does your
organization monitor allowable costs to ensure they are charged
to the grant within the specified period. (40 CFR
30.28, 40 CFR 31.23)
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8. Does your financial management system(s) report and
provide for a comparison of outlays or grant project
expenditures, with budget amounts for each grant project/award or
have the capability to do so? (40 CFR 30.21
(b)(4); 40 CFR 31.20(b)(4)).
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Does your organization have budgetary controls to
preclude incurring excess expenditures? (40 CFR
30.21(b)(3) and (4); 40 CFR 31.20(b)(4)).
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Does your accounting system have provisions for
reviewing and monitoring project budgets and program plans, and
reporting and rectifying deviations that may occur in them? (40
CFR 30.25 (b); 40 CFR 31.20(b)(4) and 31.30).
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Do you have a current audit? (40 CFR
30.26 (a) or 40 CFR 31.26).
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EPA form number 6600-01
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12. If your organization expended more than $500,000 of
Federal funds in the most recent fiscal year, did you obtain an
audit in accordance with OMB Circular A-133? (40
CFR 30.26 (a), 40 CFR 31.26(a)).
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13. If your organization had an A-133 Audit performed,
were there any findings, material weaknesses or reportable
conditions identified? If there were, briefly explain or provide
a copy of the findings section and your corrective actions taken.
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14. If your organization requests reimbursement for
indirect costs under the grant award, does your organization have
an approved indirect cost rate? (OMB Circular
A-122 / 2CFR Part 230, Appendix A, Section C and D; OMB Circular
A-87 / 2CFR Part 225, Appendix E or OMB Circular A 21 / 2 CFR
220, Appendix A,, Section G).
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15. Does your organization have written procedures for
drawing grant funds and issuing payments? 40 CFR
30.21 (b)(5) and 30.22 (b); 40 CFR 31.20(b)(7) and 31.21 (b) and
(c) Note: Payment requests should be restricted to
immediate needs, i.e. drawing down funds 3 to 5 working days in
advance of disbursements.
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16. What type of accounting and financial management
system(s) does your organization use? Name of automated system(s)
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17. Are accounting records supported by source
documentation (40 CFR 30.21 (b)(7); 40 CFR
31.20(b) (6))
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B.
Personnel/Timekeeping (Ref:
OMB Circular A-122 / 2CFR Part 230, Appendix B, section 8, OMB
Circular A-87 / 2CFR Part 225, Appendix B, section 8 or OMB Circular
A 21 /
2 CFR 220, Appendix A,
section J, paragraph 10)
Many of these questions have “Yes” or “No”
answers. For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
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1. Does your organization have written payroll policies
and procedures?
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EPA form number 6600-01
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Do your employees record: actual hours worked directly
on all projects, indirect or administrative time not charged
directly to a project, and leave taken?
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For those employees required to work away from the
office, are actual hours worked documented?
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Do payroll registers and reports match up with costs for
each employee whose compensation is charged to an assistance
agreement?
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Are timesheets required to be signed by the individual
or supervisor?
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C. Personnel/Payroll
Many of these questions have “Yes” or “No”
answers. For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
Does your organization’s written policies and procedures
provide for the following controls for the payroll function?
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Does the policy provide adequate separation of duties?
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2. Are salaries and wage rates established, authorized and
approved in your organization to ensure equity?
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3. Does your payroll process ensure that all deductions
from employee’s salaries are authorized by the employee,
and proper?
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How are payrolls distributed?
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EPA form number 6600-01
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5. If checks are distributed manually, are there
sufficient controls to ensure that payroll checks are distributed
to the correct employee?
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D.
Travel (Ref:
OMB Circular A-122 /
2CFR Part 230,
Appendix B, sections 51, OMB Circular A-87/ 2 CFR 225, Appendix B,
section 43 or OMB Circular A 21 / 2 CFR 220, Appendix A,
Section
J, para 53 )
Many of these questions have “Yes” or “No”
answers. For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
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1. Does your organization have written travel policies and
procedures?
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Are internal controls in place to ensure that employees
follow your organization’s travel policy, i.e. levels of
review prior to authorizing payment and that the travel was
associated with the specific grant project?
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Are internal controls in place to ensure that travel and
time reporting support the employee’s activities while on
travel?
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4. Do the policies and procedures include provisions to
ensure that travel costs are allowable, allocable and reasonable
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E. Matching, Cost Sharing, In-Kind Contributions and Program
Income
40 CFR Part 30.23 (a) to (i) and 40 CFR 31.24 (a) to (e)
provides criteria on the acceptability, purpose, and types of
contributions made in relation to cost sharing or matching purposes,
and the support for such. 40 CFR 30.24 and 31.25 addresses the
accounting for Program Income related to Federally funded projects.
Many of the questions below have “Yes” or “No”
answers. For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
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Does your organization currently have any Matching, Cost
Sharing and/or In-Kind costs included in any active awards or
anticipate any of these types of costs in the foreseeable
future? No _____ (Skip this entire section) Yes ____ Please
complete the rest of this section.
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EPA form number 6600-01
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Do any of the matching costs come from another federal
grant(s)? (If Yes, it must be authorized in the terms and
conditions of the assistance agreement)
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Are these costs identified in the approved grant project
budget?
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Does your organization track, record, report and verify
these costs?
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Are all matching costs verifiable from accounting records
and valued according to applicable OMB Circular cost principles?
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40 CFR Part 30.24 or Part
31.25 OMB Circular A-122 /2CFR Part 230, Appendix B, paragraphs 8 &
12; OMB Circular A-87 / 2CFR Part 225, Appendix B, paragraphs 8 &
12 or OMB Circular A 21 / 2 CFR 220, Appendix A, section J paragraph
15 refer to donations, contributions and program income.
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Has any program income been used to satisfy the
recipient’s contribution for any current award or added to
the funds committed for the project?
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Is there a term and condition in the award that permits
the use of program income for match requirements or for adding
it to the funds committed to the project?
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If there is no term and condition, has the program income
been deducted from the total allowable project cost?
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F. Procurement/Contracts/Subagreements
Many of these questions
have “Yes” or “No” answers. For “Yes”
answers, please provide the specific reference to your policies and
procedures. Please explain all “No” and “Not
Applicable” answers.
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1. Does your organization have written procurement
policies and procedures?
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2. Has your organization awarded contracts or
subagreements under any of the award agreements being reviewed?
(Agreements refer to subgrant(s). Subgrant(s) mean an award of
financial assistance in the form of money, or property in lieu of
money, made under a grant by a grantee to an eligible subgrantee,
subrecipient or by a subrecipient to a lower tier subrecipient.
This includes financial assistance when provided by contractual
legal agreement, but does not include procurement purchases of
goods and services.) (40 CFR 30.2(ff) or 40 CFR
31.3)
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3. Were contracts awarded in accordance with your organization’s
contracting policy and does this policy comply with 40 CFR Part 30.40
to 30.48 or Part 31.36 & .37, as described below:
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a) Contains a written code of conduct that addresses
conflict of interests and disciplinary actions (40
CFR 30.42; 40 CFR 31.36(b)(3))
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b) Provides for competing transactions in a free and open
manner. (40 CFR 30.43; 40 CFR 31.36(c))
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c) Provides for: a review to avoid unnecessary purchases,
a review of lease vs. purchase alternatives (when appropriate),
conducting solicitations with a clear scope of work and bidder
requirements, conserving natural resources, and utilizing small,
MBE and WBE firms when possible. (40 CFR 30.44; 40
CFR 31.36(c)(3))
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d) Requires performing and documenting a cost analysis for
sole source procurements. (A cost analysis is the review and
evaluation of each element of cost to determine reasonableness,
allocability and allowability when you do not have other
proposals to compare costs against.) (40 CFR
30.45; 40 CFR 31.36(f))
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e) Requires performing and documenting a price analysis
for competitive bidding and small purchase procurement actions.
(A price analysis may be accomplished in various ways, including
the comparison of price quotations submitted, market prices and
similar indicia, together with discounts.) (40
CFR 30.45; 40 CFR 31.36(f))
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EPA form number 6600-01
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f) Requires documenting the basis for all procurement
selections, justifying a lack of competition and basis for award
cost and price. (40 CFR 30.46; 40 CFR 31.36(b)(9))
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g) Provides for the Grantor’s pre award review of
the procurement when the award or contract modification exceeds
$100,000, is not competed, or only one bid is received. (40
CFR 30.44(e); 40 CFR 31.36(g)(2)
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h) Discusses purchase/agreement /contract cost thresholds
(small purchases vs. major procurements) and personnel required
to approve procurements.
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i) Has provisions that no contract or sub award will be
entered into with parties that are debarred, suspended or
excluded from Federal assistance programs.(40 CFR
30.13; 40 CFR 31.35)
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4. Do any of your organization’s contracts for grant
projects exceed the Federal Small Purchases threshold,
($100,000)?
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5. If Yes, did EPA request to review the contract prior to
award? (40 CFR 0.44(e); 40 CFR 31.36(g)(2)).
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6. If Yes, did EPA provide written comments?
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7. Does your organization use a pre-qualified list of
persons, firms or products to acquire goods and services?
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8. Did your organization follow its procurement policies
to place and update vendors on the list?
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EPA form number 6600-01
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Has your organization established an affirmative
procurement system for recycled materials and compliance with
environmental statutes? (40 CFR 30.16; 40 CFR
31.13).
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10. Does your organization have internal control processes
to ensure that only required goods and services are acquired in
quantities needed? (40 CFR 30.44(a)(1); 40 CFR
31.36(b)(4)).
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11. Does your organization have internal control processes
to ensure that only acceptable goods and services are paid for
by the accounting/finance department? (40 CFR
30.21(b)(6)); 40 CFR 31.20(b)(5))
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12. Does your organization have guidelines for documenting
its contract files?
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13. Has your organization awarded contracts to consultants
under current assistance agreements?
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Are internal controls for consulting agreements in place
to ensure that your organization does not charge EPA assistance
agreements more than the authorized direct salary cap? (40
CFR 30.27(b); 40 CFR 31.36(j)
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15. Do your consulting agreements specify the services to
be provided, engagement duration, reporting requirements, work
location and pay rates including base rate, fringe benefits and
overhead?
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G. Small Businesses, Minority Owned Firms, Women’ Business
Enterprises and Labor Surplus Area Firms, (Where applicable). (40
CFR 30.44(b), 40 CFR 31.36(e))
For “Yes” answers, please provide the specific reference
to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
EPA form number 6600-01
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Yes, date of the last
submittal to EPA
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Date
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No, Please Explain
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Does your organization submit timely reports (MBE/WBE
Reports) to EPA, on business activities with these types of
firms?
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H. Property Management (40
CFR 30.30 through 30.37, 40 CFR 31.31 & 40 CFR 31.32)
Many of these questions have “Yes” or “No”
answers. For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
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1. Does your organization have written property management
policies and procedures?
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2. Has your organization purchased capital equipment on
any of its active assistance agreements? ) Yes ___ (Please
complete this section) No ___ (Go to Section I)
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Equipment, under the Federal Guidelines, is equipment that is
considered tangible items with a useful life greater than one year
and greater than $5,000 in value. Grantees may have limits that are
different then the Federal Guidelines. That is acceptable as long as
the limits are not greater then the Federal Guidelines.
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3. Does your organization have an inventory control
system? (40 CFR 30.34; 40 CFR 31.32)
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4. Does your organization maintain property records that
identify equipment purchased, either entirely or partially, with
Federal funds? (40 CFR 30.34(f); 40 CFR 31.32(d)).
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5. Does your organization perform a property inventory at
least every two years? Date of last inventory:
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6. Does your organization maintain records of property
dispositions?
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EPA form number 6600-01
I.
Internal Controls
Many of these questions have “Yes” or “No”
answers. For “Yes” answers, please provide the specific
reference to your policies and procedures. Please explain all “No”
and “Not Applicable” answers.
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1. Does your organization have policies and procedures to
ensure compliance with the cash management requirements in 40 CFR
Part 30.21 (b)(3) and 40 CFR 31.20((b)(3)?
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a. Does your organization have an internal auditor, audit
staff or someone on the Board of Directors that provides for an
independent review of the accounting and financial management
process, cash receipts and payments, and safeguarding of assets?
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2. Does your organization have policies and procedure to
ensure compliance with closing out assistance awards after the
performance and budget periods. (40 CFR 30.71 and
40 CFR 31.50)
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3. Does your organization have a process in place to ensure
compliance with the Programmatic Term and Conditions in the following
areas:
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a. Submitting programmatic progress reports;
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b. Establishing and obtaining approval of a Quality Action
Plan, if required;
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c. Establishing a process to track, monitor and report on
Environmental Results
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The
annual public reporting and recordkeeping burden for this collection
of information is estimated to average 30 hours per respondent. If
you wish to comment on the Agency’s need for this information,
the accuracy of the provided burden estimates, and any suggested
methods for minimizing respondent burden, including the use of
automated collection techniques, send them to US EPA, Collections
Strategies Division (2822T), 1200 Pennsylvania Ave. NW, Washington,
DC 20460.
EPA form number 6600-01
File Type | application/msword |
File Title | EPA ADMINISTRATIVE AND FINANCIAL |
Author | JLUCIA |
Last Modified By | Rick Westlund |
File Modified | 2007-09-13 |
File Created | 2007-09-13 |