The information presented here is meant to assist you in closing out your Public Telecommunications Facilities Program (PTFP) construction or planning grant. We urge you to read it carefully and to refer to the appropriate sections again as you prepare each item for your close-out. We encourage you to call your Program Officer at (202) 482-5802 if you have any questions.

The documents you need to submit in order to close out your grant are described in the sections that follow. Also included is a checklist on which you can record relevant information about your close-out. All of the items on the checklist are important to the close-out process. We suggest you print out one for your grant as soon as possible and refer to it as you prepare your close-out.

• is due within 90 days of the completion of the grant project or the expiration of the Grant Award Period, whichever comes first; and



• must include an original and one copy of all documents, with the full grant number (e.g., 99-01-99999) on each document.

Failure to provide the required information on time and in full not only creates unnecessary problems for you and needless work for the PTFP staff, but also puts your project out of compliance with the terms and conditions of your grant award. Being out of compliance can result in -

• termination of the award,



• establishment of an Account Receivable for all Federal funds paid to your organization, and



• denial of future grants to your organization.

• Certification that the project has been completed satisfactorily and insurance coverage obtained.
• Final inventory of all equipment acquired as part of the grant project.
• A priority lien on all equipment in the project.
• Any other documentation relevant to the project, as required.

PLEASE NOTE CAREFULLY:

• Under OMB rules, close-out documents and financial reports cannot be accepted even one day after the end of the 90-day close-out period. If you are late, you must seek a retroactive extension of the close-out period. Your request must be supported with justification in the form of an explanation of why you were unable to file your close-out on time.



• In addition, failure to submit your close-out package within the 90-day period can result in the establishment of an account receivable for all Federal funds paid to your organization.



• All documents except the lien form should be submitted in DUPLICATE with ORIGINAL SIGNATURES where required (please also include a photocopy of each lien form).



• A copy of the approved final inventory must be stapled to each lien document when it is filed.

Closing Out Construction Grants

Review of Close-Out Documents

The Federal Interest Period

	
		[Program Officer's Name]
		NTIA/PTFP
		Room 4812
		U.S. Department of Commerce
		1401 Constitution Avenue, NW
		Washington, DC  20230
	

The National Institute of Standards and Technology (NIST), Grants & Agreements Management Division (GAMD), is the Commerce Department's Federal Grants Office and is responsible for all administrative and financial aspects of closing out your grant award. The reports you submit to GAMD at close-out are:

		[Grant Specialist's Name]
		National Institute of Standards and Technology
		Office of the Chief Financial Officer
		Grants & Agreements Management Division
		100 Bureau Drive, Mail Stop 3580
		Gaithersburg, MD  20899-3580

	

The name of your organization's GAMD Grants Specialist is listed in the Special Award Conditions of your grant award document.

As noted above, all construction grant close-outs include at least three separate documents — a certification of completion and insurance coverage, a final inventory, and a priority lien. Here we discuss each of the three documents in turn.

If additional documentation is required, PTFP will let you know.

The First item that must be included in your close-out documentation is certification that the project has been completed and that all of the terms and conditions of the award have been complied with.

The certification should be in the form of a letter addressed to William Cooperman, Director, Public Broadcasting Division, and must refer to your full grant number (e.g., 99-01-99999). The letter should be signed by the same person who signed the Financial Assistance Award (Form CD-450) to accept the grant or by that person's successor or superior. The letter should certify specifically that your organization has:

	complied with all of the terms and conditions of the grant;
	acquired all of the facilities specified in the grant and that they have been installed, are in operating order, and being used to provide public telecommunications services in accordance with the project as approved by NTIA;
	obtained all FCC authorizations necessary to operate the project apparatus;
	obtained and will maintain adequate insurance to protect the Federal interest in the event of loss through casualty;
	acquired all necessary site rights required for the project; and
	attached a complete and accurate final inventory of equipment and final accounting of all project expenditures.

Please submit two copies of the certification.

You must supply two copies of a final inventory of all equipment (whether bought or donated) acquired as part of your PTFP-funded grant project. The inventory you submit will be compared with the equipment list approved as part of the Grant Award, along with any amendments approved in writing by the National Institute of Standards and Technology, Grants & Agreements Management Division (GAMD) during the project period.

The inventory must include the following information for each item of equipment (an example of the format to use appears below):

	a brief description of the item (e.g., "color camera", "CD player", "audio production console", "master control switcher");
	the make and manufacturer's model number;
	manufacturer's serial number;
	the inventory number that your organization has assigned to the item (this number and the NTIA/PTFP grant number must both be on a label attached to the item);
	the quantity purchased of each item;
	the per-unit cost of the item, if applicable; and
	the total price of the item.

Taxes, Shipping, Installation, and Other Project Costs

Sales taxes and reasonable shipping charges may be claimed for equipment approved for a PTFP project. (Some states may waive sales taxes if the item is paid for with Federal funds.) Labor costs for project equipment installation can be claimed only when authorization was included in the award document or in an amendment approved in writing by GAMD.

• Sales tax charges are usually included in the cost of an item.


• When many items are purchased on a single invoice or purchase order, the sales taxes may be shown as a separate entry to cover that group of equipment items.


• Sales tax charged may be grouped and listed as a single item at the end of the equipment list, when appropriate.

• Shipping charges are usually included in the cost of an item.


• When many items are purchased on a single invoice or purchase order, the shipping charge may be shown as a separate entry to cover a group of equipment items.


• Shipping charges may be grouped and listed as a single item at the end of the equipment list, when appropriate.

• A number of small hardware items that do not relate to any one single item may be grouped in the inventory under a heading such as "Miscellaneous installation hardware" as long as it is made clear what sort of items make up the "miscellaneous" grouping.
• We repeat: installation labor costs can be claimed ONLY WHEN AUTHORIZATION WAS INCLUDED IN THE FINANCIAL ASSISTANCE AWARD DOCUMENT OR IN AN AMENDMENT APPROVED IN WRITING BY GAMD.
• Installation labor costs - when allowed - should be organized by payee and reported in the same detail as equipment.

• Other project costs can be claimed only when authorization was included in the Financial Assistance Award document or in an amendment approved in writing by GAMD.
• Other project costs - if authorized - should be arranged by payee and reported in the same detail as equipment items.

Please provide a heading that includes the name of your organization and the complete NTIA/PTFP grant number (e.g., 99-01-99999). Please repeat the heading on each page of the inventory and number the pages.

The Final Inventory list itself should be divided in half vertically, as shown in the example below. The left hand side should reproduce the equipment list from the award document; the right-hand side should show what was actually acquired.

Each major item of equipment should be listed separately. In deciding what to include as major inventory line items, you should strike a balance between encompassing too much in a single entry (e.g., "six microwave hops...$360,000") and breaking entries down into unmanageable detail (e.g., "twelve wing nuts...$1.19).

Minor equipment items, however, may be included in the cost of the major item to which they relate. You should note what sub-items are included in the total item cost. Any item that requires its own inventory number should be listed separately on the Final Inventory.

You should include brief explanations of any aspect of the Final Inventory that is unusual and might, therefore, be questioned.

Total Project Cost

The total amount of the Final Inventory (including sales taxes, shipping, installation charges, and any other approved project costs) should equal the total reported on the final financial report (SF-269) submitted to the National Institute of Standard and Technology, Grants & Agreements Management Division.

Please submit TWO copies of the final inventory

You must mark permanently all equipment included in the project to ensure accurate identification and accurate reference to inventory records. Even if your organization does not normally assign inventory numbers to items costing under a specific dollar amount, you must still assign inventory numbers to all equipment items for NTIA's purposes.

A non-removable label (or other means of identification) should be attached to the equipment where it can be seen easily. The label should contain your organization's inventory number plus the NTIA/PTFP grant award number.

Transmission antennas should be assigned an inventory number. The number should be posted in the transmitter shelter with an appropriate identification.

The requirement to submit a certificate from your insurance carrier or your risk manager has been dropped from the close-out requirements. This does not mean that you no longer have to insure equipment acquired as part of a PTFP grant.

You still must have insurance so that, in the event of loss, you will be able to continue the project by replacing equipment promptly. The insurance must protect the equipment from common hazards (fire, theft, etc.). Flood insurance should be carried in a community where such insurance is available when the grant equipment is to be located in an area that has been identified by the Secretary of Health and Human Services as having special flood hazards.

Although you no longer have to provide a certificate from your insurance company or risk manager, you must certify that your organization has - and will maintain - the required coverage. This certification is part of the letter of certification.

The Federal government retains a priority reversionary interest in all equipment you acquire as part of the project. The Federal interest extends from the initial receipt of the equipment through a ten-year period after the project is completed. This interest is secured through a lien document.

You may have been required to file an initial lien at the start of your Grant Award Period. This lien may have been revised to reflect amendments to your approved equipment list during the Grant Award Period. Regardless of the number of lien documents you may have filed during the Grant Award Period, you are required to submit a completed lien form as part of the close-out documentation.

• This lien must cover all equipment included on the approved final inventory.
• This lien must show precise information about each item of equipment acquired, including:
• manufacturer, model, and model number;
• how many of each item was acquired;
• manufacturer's serial number;
• your organization's inventory number; and
• cost.

It would be premature for you to submit a fully-recorded final lien with the close-out documents, because PTFP has to approve the final inventory attached to the lien and GAMD must sign the form before it is recorded. Even if the lien form in your state does not require a signature by the secured party, you must submit the form with the attached inventory for PTFP and Grants Office approval before you file it.

Uniform Commercial Code (UCC) Forms

Most grantees use UCC (Uniform Commercial Code) forms for the final lien. In some states a chattel mortgage is used. UCC forms differ slightly from state to state. They are usually available from an attorney, from a bank's loan department, or from an office supply store.

If required, an initial lien is usually submitted on a UCC-1 form. Subsequent lien forms that revise the equipment list are usually done as an amendment to the original lien and are prepared on whatever form is required in your state.

Completing the UCC Form

After review by NTIA/PTFP, the Grants & Agreements Management Division (GAMD) will sign the lien document for the "Secured Party" and return it to you. You must then file it at recorder(s) office(s) in the jurisdiction(s) where the project equipment will be located and where your headquarters are located, if different. This may require the preparation of more than one lien document.

Once filed, the secured party's copy of the lien, with the recording office stamp clearly visible, must be returned promptly to:

	[Grants Specialist's Name]
National Institute of Standards and Technology
Office of the Chief Financial Officer
Grants & Agreements Management Division
100 Bureau Drive, Mail Stop 3580
Gaithersburg, MD  20899-3580

When Federal Communications Commission (FCC) authorization is required for a grant project, the authorization is usually the subject of a Special Award Condition placed in the Grant Award document and worded along the following lines:

If you have already supplied FCC authorizations to NTIA/PTFP to fulfill a Special Award Condition, you need not resubmit the documents as part of the Close-Out. Your Program Officer will let you know if additional FCC documents are required.

If you have already supplied the necessary opinion letter to NTIA/PTFP to fulfill a Special Award Condition for site rights, you need not re-submit it as part of the Close-Out. Your Program Officer will contact you if additional material is required.

Construction Grant Close-Out Checklist

 

Supply an original and one copy of all documents except the lien form, with the full grant number (e.g., 99-01-99999) and original signatures where required on both copies. Attach a copy of the inventory to each lien document, and please include a photocopy of each lien document.

	Grant Award Number:		___________________________________
	Grant Award Start Date:		___________________________________
	Grant Award Ending Date:		___________________________________
	Extended to:		___________________________________
	Close-Out due:		___________________________________
	Grant Amount:		___________________________________
	Local Matching Share:		___________________________________
	Total Project Cost:		___________________________________

		DUE		SENT
Certification of Completion		____________		____________
Final Inventory		____________		____________
Lien (with copy of inventory attached)		____________		____________
Site Certification (if required)		____________		____________
FCC Documents (if required)		____________		____________

PTFP Program Officer:    _________________________________
(Phone: 202/482-5802)

GAMD Grants Specialist:   _________________________________
(Phone: 202/482-1370)

Review of Close-Out Documents

NTIA/PTFP reviews all close-out documents to be sure that the project was completed in accordance of the terms and conditions of the award. The program may request clarification or revision of material submitted in your package of close-out documents. Your prompt response will assist in the timely completion of the close-out process.

All grant recipients should be aware that failure to provide additional requested close-out information in a timely manner can result in

• the establishment of an Account Receivable for all Federal funds paid to your organization and
• the denial of future grants to your organization.

Final Inventory

 

Items included on the final inventory and not approved for purchase in the Financial Assistance Award document or in a subsequent amendment will be removed from the final approved inventory. This may result in a requirement to refund Federal funds already paid to your organization.

It is worth repeating something said earlier: inventories will not be amended retroactively as part of closing out a grant in order to cover items purchased without prior written authorization from the National Institute of Standards and Technology, Grants & Agreements Management Division.

The Federal Interest Period

Your responsibility to the Federal government through the Department of Commerce does not end when the National Institute of Standards and Technology, Grants & Agreements Management Division informs you that your close-out has been completed. This section summarizes some of the requirements imposed on grantees in the years after a grant is closed out.

Retention of Records

 

 

Federal regulations require that your organization keep financial records, supporting documents, statistical records, and all other records pertaining to the grant project for three (3) years after your final financial status report has been accepted. If any litigation, claim, or audit is started before the expiration of the three-year period, all records must be kept until all litigation, claims, or audit findings involving the records have been resolved. Grant recipients must keep the following records intact and accessible for inspection at any time:

(1)	A complete and itemized inventory of all public telecommunications facilities under the control of the grantee, whether or not financed, in whole or in part, with Federal funds;
(2)	Complete and current financial records that fully disclose the total amount of the project; the amount of the grant; and the amount, nature and sources of all non-Federal funds associated with the project; and
(3)	All records specified in Office of Management and Budget Circular A-110 (for educational institutions, hospitals, and non-profit organizations) and 15 CFR Part 24 (for state and local governments).

Project equipment must be marked in a permanent manner to assure easy and accurate identification and reference to inventory records. The marking includes the PTFP grant number and a unique inventory number assigned by the grantee.

Inspections

 

 

Grantees must permit inspections at any time during normal business hours by NTIA and the Comptroller General of the United States, or their authorized representatives, of the public telecommunications facilities acquired with Federal financial assistance and of any books, documents, papers, and records relating to those facilities.

Annual Status Reports for Construction Grants

 

 

Organizations that have received construction grants from NTIA/PTFP are required to submit an Annual Status Report for every grant project that is in the Federal interest period. By statute, this is the 10-year period during which the Federal government retains a reversionary interest in all equipment purchased under the project. The Federal interest period begins with the project completion date, as established by NTIA/PTFP during the close-out procedure.

Annual Status Reports are due on or before April 1 in each of the ten years of a grant's Federal interest period. If you have more than one grant to report on, you may submit a single report as long as it shows clearly the full grant number of each award you have in the 10-year Federal interest period.

In a conspicuous space at the beginning, the report should be identified as an Annual Status Report, with the full, nine-digit PTFP grant number (e.g., 99-01-99999).

In the Annual Status Report, the grant recipient must certify:

	That it remains an eligible entity, as defined in the PTFP Rules.
	That it continues to use the equipment purchased under the grant for the original purposes of the grant.
	That it continues to possess all FCC authorizations necessary for the project.
	That all equipment purchased under the grant continues to be protected by adequate insurance coverage. [Note: You are no longer required to submit a certificate from your insurance carrier or risk manager.]
	That it remains in compliance with all of the terms and conditions of the grant. If the grant was awarded before FY 1988, then the terms and conditions are stated in the PTFP Rules (see 15 CFR 2301.28 [1985-87]). If the grant was awarded in FY 1988 or thereafter, the terms and conditions are found in Part V of the application form, "Assurances" (contained in Attachment B for applications filed during FY 88-90). Beginning with the FY 1988 grant awards, these assurances are fully incorporated into the Financial Assistance Award document as the grant's terms and conditions at the time the grant is awarded.
	That no significant changes have occurred during the reporting period with respect to any of the terms and conditions of the grant. Or that changes have occurred (for example, has the recipient experienced any significant change in its corporate structure?). Any such changes must be reported.

	The recipient must provide information as to whether any discrimination complaints are pending against it and whether any recent adverse judgments have been rendered against it because of discriminatory practices. If a discrimination complaint is pending, the recipient should provide a brief description of the complaint and its status. If any adverse judgment has been rendered, the recipient should summarize that judgment and describe what affirmative action has been taken or is being taken to remedy the effects of the adjudged discrimination.
	If the recipient is a state or municipal agency, non-profit institution, or a college or university, then discrimination complaints and recent adverse judgments must be reported for the entire organization -not just for the radio or television station. However, state or municipal agencies should report discrimination complaints/adverse judgments only for the agency that actually receives the Federal grant money, not the entire state or municipal government.
	IF THE RECIPIENT IS AN ACADEMIC INSTITUTION, it must certify that the institution will not discriminate in its admissions policies nor in the opportunities it affords to persons to participate in the receiving or providing of services. This certification is applicable to the entire academic institution, not just to the entity (usually, as noted above, a radio or TV station) that was the subject of the grant.

The Annual Status Report should be signed by an official of the recipient organization who is legally authorized to make such certifications for it. In a college or university, this is often the president or the head of the grants and contracts office. A nonprofit institution will often have its president sign.

Annual Status Reports should be sent to the following address:

	
		William Cooperman, Director
		Public Broadcasting Division
		National Telecommunications and Information Administration
		U.S. Department of Commerce
		1401 Constitution Avenue, N.W., Room H-4812
		Washington, D.C.  20230

A SAMPLE ANNUAL STATUS REPORT APPEARS BELOW TO ASSIST YOU IN
PREPARING YOUR REPORTS

Sample Annual Status Report Letter

William Cooperman
Director
Public Broadcasting Division
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue, N.W., Room 4812
Washington, DC 20230

Subject:		Annual Status Report: April 1, 2XXX - March 31, 2XXX
		PTFP Grant #99-02-99999
		Station KBBB-TV
		Eastern State University
		Anytown, State 00000

Dear PTFP Director:

With respect to the above-referenced grant, we hereby certify the following:

• That Eastern State University remains an eligible entity as specified in the PTFP Rules and Regulations.
• That the equipment purchased under the grant continues to be used for the original purposes of the grant.
• That Station KBBB continues to have all FCC authorizations necessary for the grant project.
• That all equipment purchased under the grant continues to be protected by adequate insurance coverage.
• That Eastern State University remains in compliance with all the terms and conditions of the grant.
• That no changes have occurred during this reporting period with respect to any of the terms and conditions of the grant.

Sincerely,

Thomas A. Anyone
President

Continuation of the Lien

 

PTFP construction grant recipients are required to take steps to ensure that the Federal government's position as primary secured creditor is fully protected for the entire 10-year period of Federal interest. This protection is secured by a lien document, generally a UCC-1 financing statement, the final version of which is recorded during the grant close-out procedure.

Many states, however, do not extend such protection through the Federal interest period under a single lien document. In those states, continued protection is secured by recording a continuation statement. Recognizing the need for and recording of continuation statements is your responsibility. If you are located in any state except those listed below, you must continue to protect the Federal interest by filing a continuation of the final lien at the appropriate interval(s).

All states require renewal of the lien after five years, with the following exceptions:

	Arizona		6-year term
	Maryland		12-year term
	Tennessee		20-year term
	Louisiana		no time limit
	Puerto Rico		no time limit
	Guam		NTIA has no information
	American Samoa		NTIA has no information

Recognizing the need for, preparing, and recording continuation documents is your responsibility. To help you with this, we suggest that you enter the date the lien was recorded ("stamped") on the checklist that follows.

Checklist for Federal Interest Period

	Grant Award Number:	_____________________________
	Beginning of the 10-year
	Federal interest period:	_____________________________
	Date Final Lien filed:	_____________________________
	Lien expiration date:	_____________________________
	Certified copy to GAMD:	_____________________________
	Lien continuation filed:	_____________________________
	Copy sent to PTFP:	_____________________________

Annual Status Report Filings

		DUE	SENT
	First year	April 1, 20__	____________
	Second Year	April 1, 20__	____________
	Third Year	April 1, 20__	____________
	Fourth Year	April 1, 20__	____________
	Fifth Year	April 1, 20__	____________
	Sixth Year	April 1, 20__	____________
	Seventh Year	April 1, 20__	____________
	Eight Year	April 1, 20__	____________
	Ninth Year	April 1, 20__	____________
	Tenth Year	April 1, 20__	____________

Revised 28 September 2004