6600-01 EPA Administrative and Financial Onsite Review Questionn

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.
1. Who or which office(s) in your organization is/are responsible for reviewing, approving and signing
applications, awards and amendments?

2. Who or which office(s) in your organization is/are responsible for monitoring and overseeing
assistance agreements once received from EPA?

3. Do you have a current Organizational Chart? Show or explain any non
profit or for profit organization and/or entities your affiliated with.

Yes

No

N/A

4. How does your organization keep up-to-date on federal regulations, legal decisions, OMB Circulars,
etc.?

5. Does your organization have provisions for seeking written prior approvals
for specific revisions, from the awarding agency under certain conditions?

Yes

No

N/A

(40 CFR 30.25 (c), 40 CFR 31.30)

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6. 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?
Yes
No
N/A
a. 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.)

b. Time reporting, tracked to each project; (OMB A 122 /2 CFR Part 230,

Yes

No

N/A

c. Redistributions (Chargeback’s); (i.e., other organizational department
costs; written, established rates required)

Yes

No

N/A

d. Payroll processing and internal controls; (OMB A 122 /2CFR Part 230, Appendix

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

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 )

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)

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)

f.

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))

g. Compensatory time (if allowed). (OMB A 122 / 2 CFR Part 230, Appendix B,
paragraph 8.d)

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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

Yes

No

N/A

CFR 30.34 and 30.44, 40 CFR 31.31, 31.32 & 31.36(f))

(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)
Yes
No
N/A
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)

j.

Receipt and deposit of advanced payments (40 CFR 30.22(i)(2) and 40 CFR

Yes

No

N/A

k. Records retention. (40 CFR 30.50 and 30.53, 40 CFR 31.42)

Yes

No

N/A

l. Travel, authorizations, vouchering after the trip and, if required, trip
reporting; (OMB A 122 / 2CFR Part 230, Appendix B, paragraph 51;

Yes

No

N/A

31.21(c)&(e))

OMB A 87 / 2CFR Part 225, Appendix B, section 43; OMB A-21 / 2 CFR 220, Appendix A, section J 53)

Yes
No
N/A
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))

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))

Yes

No

N/A

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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)

Yes

No

N/A

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,

Yes

No

N/A

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))

7. Do you have the following documents for each grant award:
a. Original application and certifications; (SF 424, 424A, et al.)

Yes

No

N/A

b. Work plans and/or statement of work;

Yes

No

N/A

c. Initial award and all amendment documents;

Yes

No

N/A

d. Request for and approvals of scope and/or budget changes; (40 CFR 30.25

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

(b)&(c), 40 CFR 31.30 (a),(b) & (c)).

e. Financial Status Reports and reimbursement requests, if applicable; (40 CFR
30.52 (a)(1), 40 CFR 31.41(b))

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))

g. Progress reports; (40 CFR 30.51 (b), 40 CFR 31.40(b))

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h. Contracts / Subgrants; (40 CFR 30.46 and 30.47 and 40 CFR 31.37)

Yes

No

N/A

i. Purchases; (40 CFR 30.34 or 40 CFR 31.32 for equipment, 40 CFR 30.35 or 40 CFR

Yes

No

N/A

j. Consultant agreements; (40 CFR 30.27 (b) or 31.36(j))

Yes

No

N/A

k. Correspondence and approvals, including emails to and from EPA officials.

Yes

No

N/A

31.33 for supplies)

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.
A. Accounting
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.

Yes

No

N/A

2. Does your organization’s accounting and financial management system(s)
follow Generally Accepted Accounting Principles (GAAP)? (OMB Circular

Yes

No

N/A

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)

Yes
No
N/A
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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Yes
No
N/A
4. Does your organization’s financial management system(s) provide records
that adequately identify the source and application of funds for federallysponsored activities, such as authorizations, obligations, unliquidated obligations, assets, outlays,
income and interest? (40 CFR 30.21 & 30.22; 40 CFR 31.20,.21,&.22)

Yes
No
N/A
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)).

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

Yes

No

N/A

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)

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)

Yes

No

N/A

Yes
No
N/A
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)).

9. 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)).

Yes

No

N/A

Yes
No
10. 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).

N/A

11. Do you have a current audit? (40 CFR 30.26 (a) or 40 CFR 31.26).

N/A

Yes

No

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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)).

Yes

No

N/A

Yes
No
N/A
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.

14. If your organization requests reimbursement for indirect costs under the
grant award, does your organization have an approved indirect cost rate?

Yes

No

N/A

(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).

Yes
No
N/A
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.

16. What type of accounting and financial management system(s) does your
organization use? Name of automated system(s)

Yes

No

N/A

17. Are accounting records supported by source documentation (40 CFR 30.21

Yes

No

N/A

(b)(7); 40 CFR 31.20(b) (6))

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.
1. Does your organization have written payroll policies and procedures?

Yes

No

N/A

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2. Do your employees record: actual hours worked directly on all projects,
indirect or administrative time not charged directly to a project, and leave
taken?

Yes

No

N/A

3. For those employees required to work away from the office, are actual
hours worked documented?

Yes

No

N/A

4. Do payroll registers and reports match up with costs for each employee
whose compensation is charged to an assistance agreement?

Yes

No

N/A

5. Are timesheets required to be signed by the individual or supervisor?

Yes

No

N/A

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?
1.

Does the policy provide adequate separation of duties?

Yes

No

N/A

2. Are salaries and wage rates established, authorized and approved in your
organization to ensure equity?

Yes

No

N/A

3. Does your payroll process ensure that all deductions from employee’s
salaries are authorized by the employee, and proper?

Yes

No

N/A

4. How are payrolls distributed?

EFT

Manual Checks

Both

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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?

Yes

No

N/A

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.
1. Does your organization have written travel policies and procedures?

Yes

No

N/A

2. 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?

Yes

No

N/A

3. Are internal controls in place to ensure that travel and time reporting
support the employee’s activities while on travel?

Yes

No

N/A

4. Do the policies and procedures include provisions to ensure that travel
costs are allowable, allocable and reasonable

Yes

No

N/A

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.
Yes
No
1. 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.

N/A

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2. 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)

Yes

No

N/A

3. Are these costs identified in the approved grant project budget?

Yes

No

N/A

4. Does your organization track, record, report and verify these costs?

Yes

No

N/A

5. Are all matching costs verifiable from accounting records and valued
according to applicable OMB Circular cost principles?

Yes

No

N/A

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.

6. 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?

Yes

No

N/A

7. 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?

Yes

No

N/A

8. If there is no term and condition, has the program income been deducted
from the total allowable project cost?

Yes

No

N/A

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.
1. Does your organization have written procurement policies and procedures?

10

Yes

No

N/A

Yes
No
N/A
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)

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:
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))

Yes

No

N/A

b) Provides for competing transactions in a free and open manner. (40 CFR

Yes

No

N/A

30.43; 40 CFR 31.36(c))

Yes
No
N/A
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))

Yes
No
N/A
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))

Yes
No
N/A
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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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

Yes

No

N/A

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)

Yes

No

N/A

h) Discusses purchase/agreement /contract cost thresholds (small purchases
vs. major procurements) and personnel required to approve procurements.

Yes

No

N/A

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)

Yes

No

N/A

4. Do any of your organization’s contracts for grant projects exceed the
Federal Small Purchases threshold, ($100,000)?

Yes

No

N/A

5. If Yes, did EPA request to review the contract prior to award? (40 CFR

Yes

No

N/A

6. If Yes, did EPA provide written comments?

Yes

No

N/A

7. Does your organization use a pre-qualified list of persons, firms or
products to acquire goods and services?

Yes

No

N/A

8. Did your organization follow its procurement policies to place and update
vendors on the list?

Yes

No

N/A

31.36(b)(9))

0.44(e); 40 CFR 31.36(g)(2)).

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9. Has your organization established an affirmative procurement system for
recycled materials and compliance with environmental statutes? (40 CFR

Yes

No

N/A

Yes

No

N/A

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))

Yes

No

N/A

12. Does your organization have guidelines for documenting its contract files?

Yes

No

N/A

13. Has your organization awarded contracts to consultants under current
assistance agreements?

Yes

No

N/A

14. 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)

Yes

No

N/A

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?

Yes

No

N/A

30.16; 40 CFR 31.13).

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)).

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.

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1. Does your organization submit timely reports (MBE/WBE Reports) to EPA, on business activities
with these types of firms?
Yes, date of the last submittal to EPA

Date

No, Please Explain

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.
1. Does your organization have written property management policies and
procedures?

Yes

No

N/A

2. Has your organization purchased capital equipment on any of its active
assistance agreements? ) Yes ___ (Please complete this section) No ___
(Go to Section I)

Yes

No

N/A

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.
3. Does your organization have an inventory control system? (40 CFR 30.34; 40

Yes

No

N/A

Yes

No

N/A

5. Does your organization perform a property inventory at least every two
years? Date of last inventory:

Yes

No

N/A

6. Does your organization maintain records of property dispositions?

Yes

No

N/A

CFR 31.32)

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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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.
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)?

Yes

No

N/A

Yes
No
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?

N/A

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)

N/A

Yes

No

3. Does your organization have a process in place to ensure compliance with the Programmatic Term and
Conditions in the following areas:
a. Submitting programmatic progress reports;

Yes

No

N/A

b. Establishing and obtaining approval of a Quality Action Plan, if required;

Yes

No

N/A

c. Establishing a process to track, monitor and report on Environmental
Results

Yes

No

N/A

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. Include the OMB control number in any correspondence. Do
not send the completed form to this address.
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