Checklist · Government Contracts

Applying for, Administering, and Closing Out a Federal Grant: A Practical Checklist

31 U.S.C. § 6303

Type
Checklist
Jurisdiction
National
Date
2025-06-07
Topic
Government Contracts

A sequenced checklist for federal grant administration from application to closeout. Section A is pre-award readiness, and Section B is the first thirty days after award. Section C builds the compliance matrix. Section D governs cost charging, and Section E governs procurement. Section F covers subrecipients. Section G manages cash, reporting, and prior approvals. Section H prepares for the single audit, and Section I responds to findings and questioned costs. Section J handles closeout. Section K responds when a problem is discovered, and Section L is an annual program review.

Applying for, Administering, and Closing Out a Federal Grant: A Practical Checklist

Government Contracts > Federal Grants and Funding Compliance | Published 7 June 2025 - Updated 19 July 2025 | UpLaw - uplaw.us

How to use this

Work Sections A through C before spending a dollar. The single most consequential item is number 14 — a compliance matrix built in the first thirty days surfaces requirements while there is still time to comply with them.

SECTION A — PRE-AWARD READINESS

☐ 1. Confirm the organization can actually administer an award of this type. An award you cannot administer is worse than no award.

☐ 2. Complete and maintain system registration and the unique entity identifier — 2 C.F.R. Part 25.

☐ 3. Confirm the organization and its principals are not excluded — 2 C.F.R. Part 180.

☐ 4. Read the entire funding opportunity announcement, including review criteria and any cost sharing requirement.

☐ 5. ⚠️ Understand that cost sharing committed in an application is enforceable. Do not offer it casually.

☐ 6. Confirm you have or will obtain an indirect cost rate agreement, or document the de minimis election.

☐ 7. Confirm the financial management system can identify awards, track expenditures by award, and support the required reports.

☐ 8. Confirm time and effort documentation capability before proposing personnel costs.

☐ 9. Determine whether the instrument will be a grant, cooperative agreement, or contract — 31 U.S.C. § 6303, 31 U.S.C. § 6304, 31 U.S.C. § 6305.

☐ 10. Identify any partners and classify them as subrecipients or contractors before the application, because the classification affects the budget.

☐ 11. Complete representations and certifications accurately. Each is a representation.

☐ 12. Confirm drug-free workplace compliance — 2 C.F.R. Part 182.

SECTION B — THE FIRST THIRTY DAYS AFTER AWARD

☐ 13. ⚠️ Understand that drawing down funds accepts the terms. Read before drawing.

☐ 14. ⚠️ Build the compliance matrix (Section C). This is the highest-value hour of the award period.

☐ 15. Collect every incorporated document: general terms and conditions · agency-specific requirements · the funding opportunity announcement · the approved application and budget · the Uniform Guidance at 2 C.F.R. Part 200.

☐ 16. Identify the assistance listing number and locate the program's entry in the compliance supplement.

☐ 17. Note the period of performance and the budget period; they are frequently different.

☐ 18. Note every prior approval requirement: budget revisions above a threshold, scope changes, key personnel changes, equipment, new subawards, no-cost extensions.

☐ 19. Note every reporting requirement and its frequency, and calendar each.

☐ 20. Note any cost sharing, matching, or level of effort obligation and how it will be documented.

☐ 21. Note whether the program generates program income and how the award requires it to be treated.

☐ 22. Set up award-specific accounting codes.

☐ 23. Brief the program staff who will incur costs, not only the finance staff who will record them.

SECTION C — THE COMPLIANCE MATRIX

☐ 24. One row per requirement: the requirement · the source document · the responsible person by name · the demonstrating record · the frequency.

☐ 25. ⚠️ Assign a named person, not a department. Requirements assigned to "finance" are the ones nobody does.

☐ 26. Include: activities allowed and unallowed · allowable costs · cash management · eligibility · equipment and property · matching and level of effort · period of performance · procurement and suspension and debarment · program income · reporting · subrecipient monitoring · special tests and provisions.

☐ 27. Add award-specific items: publication and acknowledgment · data sharing · human subjects · animal welfare · environmental review · domestic preference under 2 C.F.R. Part 184.

☐ 28. Add flow-down provisions required in every subaward and contract.

☐ 29. Review the matrix quarterly and update it on any award modification.

☐ 30. Provide the matrix to the auditor at the start of the audit.

SECTION D — CHARGING COSTS

☐ 31. Test every cost against all seven elements: necessary and reasonable · allocable · within limitations · consistently treated · GAAP · not used for other federal cost sharing · adequately documented.

☐ 32. ⚠️ "Adequately documented" produces most findings. A proper cost with no record is disallowed.

☐ 33. Support personnel charges with records reflecting work actually performed, reconciled to payroll each period.

☐ 34. ⚠️ Do not charge on budget percentages without reconciliation. Identical certifications every period for years are not evidence of measurement.

☐ 35. Track committed effort across all awards and confirm no individual exceeds one hundred percent.

☐ 36. Process cost transfers promptly with contemporaneous justification. Late transfers, especially to spend down a balance, are examined closely.

☐ 37. Apply the indirect rate to the correct base as the rate agreement specifies. Verify the exclusions.

☐ 38. Confirm whether the program caps indirect recovery, and treat any shortfall correctly.

☐ 39. Obtain prior approval for equipment and capital expenditures.

☐ 40. Confirm travel complies with the organization's written policy or federal rates.

☐ 41. Treat participant support costs distinctly and exclude them from the indirect base where required.

☐ 42. ⚠️ Segregate lobbying costs. Ordinary advocacy is normal work and is not chargeable — separate accounting, not avoidance.

☐ 43. Exclude other unallowable categories: alcohol, entertainment, fundraising, fines and penalties, bad debts, and most costs of defending government proceedings — compare 41 U.S.C. § 4304 and 41 U.S.C. § 4310.

☐ 44. Confirm every cost is within the period of performance.

SECTION E — PROCUREMENT UNDER THE AWARD

☐ 45. Adopt a written procurement policy meeting the Uniform Guidance standards, and apply it consistently.

☐ 46. ⚠️ Use the federal standards, not your own purchasing policy, for federal award funds.

☐ 47. Confirm the purchase is necessary and not duplicative.

☐ 48. Select the correct method by dollar value: micro-purchase · small purchase with quotations · sealed bids · competitive proposals · noncompetitive.

☐ 49. Write specifications that do not unduly restrict competition.

☐ 50. Apply the conflict of interest standards and obtain a certification from anyone involved in selection.

☐ 51. Perform and document a cost or price analysis above the simplified acquisition threshold.

☐ 52. ⚠️ Justify any noncompetitive procurement in writing on a permitted ground — single source, public exigency, express agency authorization, or inadequate competition after solicitation. Familiarity and satisfaction are not permitted grounds.

☐ 53. Verify exclusion status before every covered transaction — 2 C.F.R. Part 180.

☐ 54. Include all required contract provisions: remedies, termination, equal opportunity, and record access.

☐ 55. Apply domestic preference requirements for infrastructure — 2 C.F.R. Part 184.

☐ 56. ⚠️ Keep a procurement file per transaction: requirement · sources considered · solicitation · responses · evaluation · price analysis · conflict certification · debarment check · executed agreement. Thirty minutes per purchase.

SECTION F — SUBRECIPIENTS

☐ 57. ⚠️ Classify by substance, not by the label on the agreement. A subrecipient carries out part of the program; a contractor provides goods or services in its normal business.

☐ 58. Document the classification analysis.

☐ 59. Include all required information in the subaward: federal award identification number · assistance listing number · amount · indirect cost rate · period of performance · all applicable requirements.

☐ 60. Flow down every applicable requirement, including exclusion verification and reporting.

☐ 61. Assess risk for each subrecipient: prior experience, audit results, personnel changes, extent of federal monitoring. Document it.

☐ 62. Set a monitoring plan proportionate to risk — report review, follow-up on findings, site visits, or agreed-upon procedures.

☐ 63. Actually perform the monitoring and document it.

☐ 64. Verify single audits where required and obtain the reporting package.

☐ 65. Issue management decisions on subrecipient findings and obtain corrective action plans.

☐ 66. Report subawards — 2 C.F.R. Part 170.

☐ 67. ⚠️ Understand that you are answerable for the subrecipient's disallowed costs.

☐ 68. Take enforcement action where warranted, and document the decision either way.

SECTION G — CASH, REPORTING, AND APPROVALS

☐ 69. Draw down only for immediate needs; minimize the interval between draw and disbursement.

☐ 70. ⚠️ Drawing more than immediate needs is a finding.

☐ 71. Reconcile drawdowns to expenditures monthly.

☐ 72. Identify and correctly treat program income — added, deducted, or applied to cost sharing as the award specifies.

☐ 73. Submit performance and financial reports on time. Deadlines are absolute.

☐ 74. Obtain prior approval before any action requiring it, in writing, and file the approval.

☐ 75. Track cost sharing contributions contemporaneously with the same documentation standards as direct costs.

☐ 76. Maintain equipment records — description, identification, source, title, acquisition date and cost, federal share, location, condition, and disposition.

☐ 77. Conduct a physical inventory of equipment at the required interval.

☐ 78. ⚠️ Renew system registration before expiration — 2 C.F.R. Part 25. A lapse stops payments.

SECTION H — PREPARING FOR THE SINGLE AUDIT

☐ 79. Determine whether expenditures exceed the threshold requiring a single audit — 31 U.S.C. § 7502.

☐ 80. Engage the auditor early.

☐ 81. ⚠️ Maintain the schedule of expenditures of federal awards continuously, not at year end.

☐ 82. ⚠️ Read the compliance supplement for each likely major program before the audit and self-test the requirements it identifies.

☐ 83. Assemble, per award: the award and terms, the compliance matrix, the budget and revisions, prior approvals, drawdown records, reports as filed, effort documentation, procurement files, and subrecipient monitoring records.

☐ 84. Prepare the summary schedule of prior audit findings.

☐ 85. Provide requested documents completely and promptly; partial productions extend the audit and expand its scope.

☐ 86. Respond substantively to draft findings; the response is published and frequently narrows the finding.

☐ 87. Prepare a corrective action plan with a named person, a specific action, and a completion date. ⚠️ Generic plans produce repeat findings.

☐ 88. Present the audit, findings, and corrective action plan to the governing body.

☐ 89. Submit the reporting package to the clearinghouse on time.

SECTION I — FINDINGS AND QUESTIONED COSTS

☐ 90. ⚠️ A questioned cost is not a disallowance. The agency issues a management decision.

☐ 91. Respond with documentation before the decision issues — the most productive stage.

☐ 92. Distinguish costs that are genuinely unallowable from those that are merely undocumented and reconstructable.

☐ 93. Reconstruct support where the underlying cost was proper.

☐ 94. Identify the appeal route for the agency — for example, 20 U.S.C. § 1234 and 20 U.S.C. § 1234a in the education context, with general authority at 20 U.S.C. § 1221e-3.

☐ 95. Preserve judicial review options under 5 U.S.C. § 706 — see Administrative Law.

☐ 96. Anticipate offset against future payments and plan cash flow.

☐ 97. Implement and document the systemic fix, not just the instance.

☐ 98. Track every finding to closure.

SECTION J — CLOSEOUT

☐ 99. Calendar the closeout deadline from the end of the period of performance.

☐ 100. Notify vendors and subrecipients well before the period ends that final invoices are due by a stated date.

☐ 101. Confirm no costs were incurred outside the period of performance.

☐ 102. Liquidate all obligations within the closeout window.

☐ 103. Submit final performance and financial reports.

☐ 104. Refund unobligated balances.

☐ 105. Account for equipment and obtain disposition instructions where the federal share exceeds the threshold.

☐ 106. Reconcile cost sharing and document that commitments were met.

☐ 107. Confirm program income was treated correctly through the end.

☐ 108. Start the record retention clock from final report submission, and note it is longer than most default schedules.

☐ 109. File the complete closeout package in the award file.

SECTION K — WHEN A PROBLEM IS DISCOVERED

☐ 110. Stop the practice and document the decision and date.

☐ 111. Preserve records and issue a hold if an investigation is plausible.

☐ 112. Quantify — what cost, over what period, on which awards.

☐ 113. Determine whether the cost is unallowable or undocumented.

☐ 114. ⚠️ Evaluate certification accuracy. Every drawdown and report is a representation — 31 U.S.C. § 3729.

☐ 115. Consider voluntary disclosure; mitigation value declines as the agency independently develops the facts.

☐ 116. Assess exclusion exposure — 2 C.F.R. Part 180 — and prepare the present-responsibility narrative: what happened, what changed, who is accountable, why it will not recur.

☐ 117. Anticipate a civil investigative demand — 31 U.S.C. § 3733 — and centralize communications.

☐ 118. ⚠️ Address retaliation risk immediately. The relator is almost always an employee who raised the issue internally first.

☐ 119. Consider the administrative remedy framework — 31 U.S.C. § 3801, 31 U.S.C. § 3802.

☐ 120. Brief the governing body.

SECTION L — ANNUAL PROGRAM REVIEW

☐ 121. Confirm registration is current and calendared — 2 C.F.R. Part 25.

☐ 122. Refresh the indirect cost rate agreement or confirm the de minimis election.

☐ 123. Re-verify exclusion status for all subrecipients and significant vendors.

☐ 124. Review the compliance matrix for every active award.

☐ 125. Test effort documentation against payroll for a sample of employees.

☐ 126. Test a sample of procurement files for completeness.

☐ 127. Confirm subrecipient monitoring actually occurred as planned.

☐ 128. Review the corrective action tracker and close what can be closed.

☐ 129. Confirm cash management practice against drawdown records.

☐ 130. Confirm records retention is meeting the longest applicable period.

☐ 131. Review the internal reporting channel and any reports received.

☐ 132. Confirm the governing body has seen the audit, findings, and corrective action plan — see Corporate Governance and Fiduciary Duties.

SECTION M — THE DOCUMENT SET, PER AWARD

Every award should have one file containing exactly this. An auditor who receives it in this order asks far fewer questions.

☐ 133. The notice of award and every amendment ☐ 134. The general terms and conditions in the version incorporated ☐ 135. The agency-specific requirements ☐ 136. The funding opportunity announcement ☐ 137. The approved application, budget, and budget narrative ☐ 138. The compliance matrix (Section C) ☐ 139. The assistance listing entry and the relevant compliance supplement pages ☐ 140. Every prior approval requested and granted, with dates ☐ 141. Every budget revision and the approval, if required ☐ 142. All drawdown records reconciled to expenditures ☐ 143. All reports as filed, with submission confirmations ☐ 144. Effort documentation for every individual charged ☐ 145. Procurement files for every transaction charged ☐ 146. Subaward agreements, risk assessments, monitoring records, and management decisions ☐ 147. Equipment records and inventory results ☐ 148. Cost sharing documentation ☐ 149. Program income records and treatment ☐ 150. All correspondence with the agency ☐ 151. The closeout package ☐ 152. The record retention date, computed from final report submission

SECTION N — QUICK REFERENCE

☐ 153. Which instrument? — 31 U.S.C. § 6303 contract · 31 U.S.C. § 6304 grant · 31 U.S.C. § 6305 cooperative agreement, with purposes at 31 U.S.C. § 6301 and guidance at 31 U.S.C. § 6307. ☐ 154. The framework — 2 C.F.R. Part 200, plus Part 25, Part 170, Part 180, Part 182, Part 183, and Part 184. ☐ 155. Allowability requires all seven elements, and documentation is the one that fails. ☐ 156. Federal procurement standards apply, not your own policy. ☐ 157. Subrecipient or contractor turns on substance, and the pass-through entity is answerable. ☐ 158. Single audit — 31 U.S.C. § 7501 through 31 U.S.C. § 7505; the compliance supplement says what will be tested. ☐ 159. Questioned cost ≠ disallowance. Respond before the management decision. ☐ 160. Fiscal law limits time and purpose — 31 U.S.C. § 1301, 31 U.S.C. § 1341, 31 U.S.C. § 1517, 31 U.S.C. § 1552; background at 2 U.S.C. § 1501. ☐ 161. Exclusion is government-wide — 2 C.F.R. Part 180 — and self-disclosure is the principal mitigator. ☐ 162. Certifications are representations — 31 U.S.C. § 3729, 31 U.S.C. § 3730; administrative remedy at 31 U.S.C. § 3801 and 31 U.S.C. § 3802. ☐ 163. Conditions must be unambiguous to bind — Pennhurst State School and Hospital v. Halderman, South Dakota v. Dole. ☐ 164. Read the award in the first thirty days. Close out cleanly in the last sixty. Those two habits prevent most findings.

SECTION O — THE FIVE FINDINGS THAT RECUR

Nearly every single audit finding in this field falls into one of five categories. Each is preventable with a specific practice.

☐ 165. Personnel costs not supported by records reflecting actual work. Prevention: a time record by award, completed by someone with direct knowledge, reconciled to payroll each period, with variances adjusted promptly rather than at year end.

☐ 166. Procurement without documented competition or a valid noncompetitive justification. Prevention: a written policy meeting the federal standards, and a thirty-minute procurement file for every transaction.

☐ 167. Subrecipient monitoring not performed or not documented. Prevention: a written risk assessment per subrecipient and a monitoring plan proportionate to that risk, executed and recorded.

☐ 168. Costs incurred outside the period of performance, or obligations not liquidated at closeout. Prevention: a notice to vendors and subrecipients sixty days before the period ends, and a closeout checklist reconciling obligations to the period.

☐ 169. Reporting late or inaccurate, and cash drawn beyond immediate needs. Prevention: a reporting calendar with owners, and a monthly reconciliation of drawdowns to expenditures.

📌 A sixth category deserves mention because it is the most disruptive and the least excusable: a lapsed system registration under 2 C.F.R. Part 25. It is not a finding in the usual sense — it simply stops payments, mid-project, until it is cured. One calendar reminder prevents it entirely.

☐ 170. The pattern across all six: none involves a difficult legal judgment. Each involves a routine administrative practice that nobody was assigned to perform.

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