TOP GRANTEE HANDBOOK
FISCAL YEAR 2001

Technology Opportunities Program


CONTENTS


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WHERE TO SEND REQUIRED REPORTS

Your Technology Opportunities Program (TOP) Program Officer (listed in the Special Awards Conditions section of your Grant Award document) should be the initial contact for all programmatic and technical matters related to your Grant Award. The information that you will submit to TOP includes:

Two copies of the materials listed above and any additional materials such as newspaper articles, press releases, conference reports, photos, videos, etc. should be mailed to your TOP Program Officer at the following address:

U.S. Department of Commerce/NTIA
TOP, Room 4096
1401 Constitution Avenue, NW
Washington, DC 20230

The Office of Executive Assistance Management (OEAM) is the Federal Grants Office within the Department of Commerce that is responsible for all administrative and financial matters related to your TOP Grant Award. The reports, forms, and other documents you will submit to your OEAM Grants Specialist (listed in the Special Awards Conditions section of your Grant Award document) include:

  • SF-3881: ACH Vendor/Miscellaneous Payment Enrollment Form
  • SF-269: Financial Status Report
  • SF-272: Federal Cash Transactions Report
  • SF-270: Request for Advance or Reimbursement

These materials should be mailed to your OEAM Grants Specialist at the following address:

U.S. Department of Commerce
OEAM, Room 6054
1401 Constitution Avenue, NW
Washington, DC 20230

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CONTACTING TOP

TOP WEB PAGE: www.ntia.doc.gov/top/
TELEPHONE: TOP Main Office (202) 482-2048
FAX: TOP Main Office
TOP Program Officers
(202) 501-5136
(202) 501-8138
EMAIL: TOP Main Office

TOP Director:
    Stephen J. Downs

TOP Evaluation Specialist:
    Francine Jefferson, Ph.D.

TOP Program Officers:
    Amy Borgstrom
    Don Druker
    Lammot du Pont
    Phillip English
    Thomas Hardy
    Steve Saleh
    Judith Sparrow

TOP Grants Assistants:
    Sean Lilly
    Edna McCormick

TOP@ntia.doc.gov


sdowns@ntia.doc.gov


fjefferson@ntia.doc.gov


aborgstrom@ntia.doc.gov
ddruker@ntia.doc.gov
ldupont@ntia.doc.gov
penglish@ntia.doc.gov
thardy@ntia.doc.gov
ssaleh@ntia.doc.gov
jsparrow@ntia.doc.gov


slilly@ntia.doc.gov
emccormick@ntia.doc.gov

send an email to someone at TOP:

Recipient:
Your Name:
Your Email:
Priority:
Subject:
Message:
 

CONTACTING THE GRANTS OFFICE (OEAM)
TELEPHONE: OEAM Main Office (202) 482-1370
FAX: OEAM Main Office (202) 482-1844


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INTRODUCTION

Congratulations on your recent grant award from the Technology Opportunities Program (TOP).

This TOP Grant Recipient Handbook is designed to assist you in understanding the basic responsibilities of TOP grant recipients, and to provide you with information and guidance in the preparation of required reports and documents. We recommend that you carefully review this Handbook, and keep it available for easy reference throughout the period that your grant is active.

TOP also encourages you to read carefully your entire Financial Assistance Award document, which contains additional information on requirements and conditions of your grant award. You should pay particular attention to the Special Award Conditions that are included with the Grant Award Document.

As you begin your TOP project, it is very important that you differentiate between your TOP Program Officer, who is responsible for programmatic and technical matters related to your grant award, and your Office of Executive Assistance Management (OEAM) Grants Specialist, who is responsible for the financial and administrative aspects of your award. Knowing and understanding the difference can help you avoid delays in processing various aspects of your award.

Included with this Handbook are two Important Reminders and Due Dates checklists with which you can track your compliance with various TOP and OEAM deadlines. All of the items on the two checklists are important to the responsible management of your TOP grant award, and we encourage you to review and refer to them frequently to ensure that your organization remains in compliance with the terms and conditions of your grant award. Should you have questions regarding any of these requirements, please contact your TOP Program Officer or your OEAM Grants Specialist.

Please note that failure to provide required reports and other information on time and in full creates an unnecessary burden for your organization and for TOP and OEAM staff. This situation also places your project out of compliance with the terms and conditions of your TOP grant award, a serious condition that may result in suspension or termination of your grant, establishment of an Account Receivable for all federal funds paid to your organization from this award, and/or denial of future grants to your organization.

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IMPORTANT REMINDERS

Project Start-Up Documentation, Quarterly Performance Reports and the Final Project Report Must be Submitted to TOP in Electronic Form

Project Start-Up Documentation, all Quarterly Performance Reports and the Final Project Report must be submitted to TOP electronically via TOP's web-based Performance Reporting System (PRS). Information and instructions on using the PRS system are included in this Handbook.

All Other Required Materials Must be Submitted to TOP in Hardcopy Form and in DUPLICATE

Please remember to submit all other required hardcopy documents and any supporting materials (including newspaper articles, press releases, etc.) to TOP in duplicate (one original and one copy).

All Required Forms and Reports to OEAM Must be Submitted in Hardcopy Form and in TRIPLICATE

Please remember to submit all required forms and reports to OEAM in hardcopy form in triplicate (one original and two copies).

Grant Award Number

Please remember to always put your full 9-digit Grant Award number (for example, "TOP Grant #55-60-I00001") on all forms or other materials that you submit to TOP or OEAM.

Valid Street Address

If you did not do so during the application process — or if your address has changed — you must provide TOP and OEAM with a complete and valid street address for your organization. Remember also to include all applicable Suite and Room numbers. Registered and express mail correspondence from TOP and OEAM cannot be delivered to a Post Office box number alone.

Changes in Address

Please make certain that the address on file with TOP and OEAM for your organization is current and correct. Please notify both TOP and OEAM immediately of any address changes.

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UNDERSTANDING YOUR GRANT AWARD DOCUMENT

Your TOP Grant Award document package contains all of the materials and information necessary for your organization to remain in full compliance with the terms and conditions of your award. It is important that you read all of these materials, and that you keep them close at hand for ready reference during the months that your project is active. Even though your organization may have had previous experience with other federal grants, it is important to remember that each federal agency and grant program is different, and that each has its own distinct reporting requirements.

CD-450: Financial Assistance Award

The first item in your TOP Grant Award package is the one-page Financial Assistance Award (CD-450) document, the formal contract signed and dated by the OEAM Grants Officer that constitutes an obligation of federal funding for your project. Your package contains three identical copies of the CD-450, each of which must be signed and dated by an authorized official from your organization. In signing these documents, your organization agrees to comply with the provisions, terms and conditions of the Grant Award. Once the CD-450 has been signed and dated, two copies must be returned to the Grants Officer within 30 days of receipt, and the third copy retained by your organization. If the two signed copies are not returned to OEAM within the 30-day period, the Grants Officer may declare your Grant Award to be null and void.

Please check to make sure that the information contained on the CD-450 is complete and accurate. If you believe that an item is incorrect, you should contact the OEAM Grants Specialist who is listed on the first page of the Special Award Conditions packet. Do not attempt to make any changes to the award document on your own.

U.S. Department of Commerce Financial Assistance Standard Terms and Conditions

The Department of Commerce Financial Assistance Standard Terms and Conditions document contained in your Grant Award package describes a number of general financial, programmatic and other Departmental award requirements with which your organization must comply.

Among the items covered in the Standard Terms and Conditions document are the following:

  • Financial Requirements: 1) A description of the Financial Reports that your organization will be required to submit to OEAM; 2) An explanation of how your organization should request a payment from your TOP award; 3) A clarification of the federal and non-federal cost sharing rule; 4) A discussion of general guidelines governing budget changes and transfers of funds among budget categories on your award; 5) A description of indirect costs; 6) A warning about incurring costs and/or obligating federal funds beyond the project expiration date; and 7) A note about grant-related tax refunds.

  • Programmatic Requirements: 1) A description of the reports and closeout documentation that your organization will be required to submit to TOP; 2) A discussion of general guidelines regarding programmatic changes related to your award; 3) A note regarding actions that might be taken in the event of unsatisfactory performance on your grant award; and 4) A statement regarding your obligation to notify TOP in the event that your organization receives other federal awards relative to the scope of work of your TOP project.

  • Other Requirements: 1) An explanation of the applicability of provisions of your award to subrecipients, subawards, contracts and subcontracts; 2) A description of organization-wide and project-related audit requirements; 3) A note regarding payment of debts owed to the federal government; 4) An explanation of various regulations regarding non-discrimination, government-wide debarment and suspension, lobbying restrictions, name checks and other requirements related to your award.

U.S. Department of Commerce Financial Assistance Special Award Conditions

The Department of Commerce Financial Assistance Special Award Conditions document in your Grant Award package contains specific information related to your particular award, reiterates some of the requirements contained in the Standard Terms and Conditions, and describes a number of requirements that must be met before federal funds from your grant award can be released to your organization.

The Special Awards Conditions document lists the names, addresses and telephone numbers of your organization's TOP Program Officer, OEAM Grants Officer, and OEAM Grants Specialist, as well as the primary contact individual for your organization. The document also describes the general nature of your funded project, and lists the agreed-upon line-item budget figures for your project by federal and non-federal share. In addition, it identifies the required components of the Quarterly Performance Reports and Closeout Documentation package that your organization will be required to submit to TOP.

For a description of the Special Award Conditions that may be specifically required of your organization, please see the Special Award Conditions section of this Handbook.

Financial Reporting Forms

Your Grant Award package will contain a number of blank forms that are to be used in submitting required financial information to OEAM. Each of the forms may be reproduced as often as necessary. These forms are as follows:

  • SF-3881: Automated Clearing House (ACH) Vendor/Miscellaneous Payment Enrollment Form

  • SF-270: Request for Advance or Reimbursement

  • SF-269: Financial Status Report

  • SF-272: Federal Cash Transactions Report

  • CD-281: Report of Government Property in Possession of Contractor

Each of these required Financial Reports and Forms is discussed in the Financial Reports and Forms section of Handbook.

Regulations, Circulars, and Policies Related to Your Grant Award Document

The front page of your Financial Assistance Award document (CD-450) contains a list of regulations, circulars and policies that may apply to your TOP grant award.

Those that have checks appearing in front of them specifically apply to your organization's award. Copies of each of these are included with your Grant Award package. For online versions of the circulars, please see:

www.whitehouse.gov/omb/circulars/.


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USING TOP'S ELECTRONIC
PERFORMANCE REPORTING SYSTEM (PRS)

Introduction to PRS

The TOP web-based Performance Reporting System (PRS) was developed to improve grantees' ability to collect data and document information pertaining to project startup, implementation, and ongoing progress in a timely and efficient way. Having such data at hand should provide grantees with a tool for ongoing self-assessment and monitoring. Also, the PRS was designed to enhance the Program's ability to collect relevant data, monitor project progress, and conduct ongoing analyses of projects and their impacts.

The PRS is intended to be a tool for both our grantees and for TOP Program Officers. It should provide improved, increased, and more timely communication between grantees and Program Officers. By collecting results data from the field in a structured format, the Program can better aggregate and assess the information provided by the different projects. The resulting analyses will assist TOP in quickly gauging its impacts and sharing the lessons learned by the funded projects.

It is our intention to assess the nature and degree of the effects that the funded projects are having at the local, state and national levels. The PRS will help grantees and TOP to assess the nature and degree of those effects on the organizations implementing the projects, other organizations that are involved with the projects, the individuals served, and the community as a whole.

The PRS is comprised of the following data collection elements: Start-up Documentation, Quarterly Progress Reports, and Close-Out Documentation. Each will be explained in subsequent sections of the Handbook.

PRS Basics

The Performance Reporting System (PRS) is a web-based reporting tool which allows grantees to submit monitoring and evaluation data electronically to TOP.

To enter your performance reports online you will need Microsoft Internet Explorer or Netscape Browser 3.0 or higher. We recommend, at least, a 28.8 modem.

There are several key features to the system that are intended to simplify your reporting requirements.

Work-in-progress. The system is designed to allow you to work on an entry, save your work in progress, leave the system and return later to pick up where you left off. This allows you to work incrementally on your reports and/or make whatever revisions and updates are necessary until you complete and submit your entire report. A PRS session is limited to a maximum of 4 hours.

Report Roll-over. The system is designed to roll data from your previous report into subsequent reports. This minimizes the time you need to spend keying data into the system.

Internal edit checks. The system contains several internal edit checks that will help you fill out the items completely and accurately.


Logging On and Using the PRS

Your organization will be mailed one set of access/submit codes for the PRS. The access codes will be composed of a ten-digit alpha-numeric ID and Password. You will also be issued a ten digit Close Password.

The ID and Password provide read and write access to the system. The Close Password is required to submit a completed report to TOP for review and acceptance. Sending your final submittal will freeze your data for that report. Until final submittal, you may leave and return to the PRS as often as you like. After final submittal, you may return to the site as often as like to view a read-only version of your report.

If you have lost or forgotten your Access/Submit codes, please contact your Program Officer. They will see that your organization is provided with new codes. If you think that an unauthorized user has gained access to your records, please contact your Program Officer immediately, and you will be provided with new codes.

TOP Review and Acceptance

Once you have submitted a completed report to TOP, your Program Officer will review your report. Your Program Officer may have questions about your report and may request that you modify your submission. Your Program Officer will re-open your report, allowing you to edit your submission. When you have completed your edits, resubmit your report (using your Close Password).

The program director will give each report a final review and accept them. At this point the system will roll to the next reporting cycle. After the program director's acceptance, you will be able to begin to enter data for your next report. We anticipate that it will take about 30 days for us to process reports.

PRS Help Desk

If you need help with the system, telephone support (via 202-482-2048) will be available Monday through Friday, 8:30 a.m. to 5:00 p.m., Eastern Standard time. Please indicate to the receptionist whether you have a technical question (can't access the site, need a new access/submit code, etc.) or a programmatic question (not sure who should be listed under "key personnel," not sure what TOP is looking for in "outcomes" section, etc.).

Technical matters will be referred to our technical support staff. If you prefer email, technical questions can be sent to our email support at PRSHelp@ntia.doc.gov. In your email, please include your award number, your organization name, and a phone number where you can be reached.

For programmatic questions, your call will be forwarded to your TOP Program Officer.

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PROJECT START-UP DOCUMENTATION

TOP requires your organization to submit project Start-Up Documentation that provides initial background information regarding your project. The purpose of the Start-Up Documentation is to establish an initial framework of information from which TOP will be able to assess the progress being made on your project during the period that it is active.

This data will also provide you an opportunity to verify the information about the project that may have changed during or since negotiations. Some of the data entered in this report will be important in filling out the quarterly reports and the final project report.

Due Date

Project Start-Up Documentation is to be submitted to TOP electronically via the TOP web-based Performance Reporting System (PRS) within 60 days after the award start date.

Content

Your organization will be expected to provide TOP with the following information and data in your project Start-Up Documentation:

  • Background Information Regarding your Organization: Primary contact and address data, organization type, etc.

  • All Project Partners and/or Subrecipients Associated with your Project

  • Project Purpose and Outcomes: The community impacts that your project is ultimately designed to achieve, and the measurable changes in your community that can realistically and logically be expected from your project.

  • Project Scope: The overall range and spectrum of activities encompassed by your project and the characteristics of your project's intended end users and indirect beneficiaries.

  • Project Implementation: The key activities and specific milestones that you expect to complete during the period that the grant is active.

  • Project Evaluation: The specific methods that will be used to evaluate your project's impact and the group that will have primary responsibility for conducting project-related evaluation activities.

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QUARTERLY PERFORMANCE REPORTS

TOP requires your organization to submit a Quarterly Performance Report (also referred to as a Quarterly Programmatic or Quarterly Technical Report) that describes project-related activities that have taken place during each calendar quarter that the project is active. The purpose of the Quarterly Performance Report is to allow TOP to track the progress being made on your project, and to provide your organization with an opportunity to document your achievements and the lessons that have been learned from your project to date. The Report also gives you the opportunity to discuss any difficulties or obstacles that you may encounter so that TOP will be in a position to help you avoid more serious problems at a later date.

Due Dates

Quarterly Performance Reports are to be submitted to TOP electronically via the TOP web-based Performance Reporting System (PRS) within 30 days after the end of each calendar quarter as follows:

  • For the Quarter ending Dec. 31, the report is due to TOP no later than January 31.

  • For the Quarter ending March 31, the report is due to TOP no later than April 30.

  • For the Quarter ending June 30, the report is due to TOP no later than July 31.

  • For the Quarter ending Sept. 30, the report is due to TOP no later than October 31.

Please remember that it is extremely important that your organization submit all Quarterly Performance Reports on time. Failure to submit Reports in a timely fashion places your organization out of compliance with the terms and conditions of your grant award, and may result in the suspension of payments associated with the grant, an effort to recover funds that have already been disbursed, and/or termination of the grant award.

If the Project Period End Date for your grant ends before the last day of a quarter, your organization is not required to submit a Quarterly Performance Report for that particular quarter. Instead, these final activities should be reported in the Final Report that is included with your Closeout Documentation.

Content

The content of your Quarterly Performance Report should reflect the current status of your project, and should be confined to the specific quarter being reported. Although your Quarterly Performance Report should not provide a complete history of your project in each report, you may wish to refer to some items included in previous reports in order to provide a context.

Your organization will be expected to provide TOP with the following information and data in each Quarterly Performance Report:

  • Key Project Personnel: Changes in key project staff during the quarter being reported.

  • Project Partners and/or Subrecipients: Changes in project partners and/or subrecipients associated with your project during the quarter being reported.

  • Project Implementation: Significant activities conducted or milestones achieved during the quarter being reported; the extent to which your project was able to complete the key activities and specific milestones that it was expected to complete during the quarter; project changes or modifications that may need to be addressed in upcoming months; and the implementation status of local TOP sites.

  • Problems and Obstacles: Any problems, obstacles or unanticipated events that your project encountered during the quarter being reported.

  • Outreach Activities: Any outreach activities that your organization used to publicize or disseminate information about your project during the quarter being reported.

  • Publications: Any articles, reports, conference presentations, video clips or other materials that discuss your TOP project. Please mail copies of this information directly to your TOP Program Officer.

In addition, Quarterly Performance Reports submitted for the Quarter ending September 30 of each year must contain information on two additional items:

  • Project Outcomes: Any significant breakthroughs that your project achieved during the previous 12 months in implementing your proposed approach, attaining specific outcomes, expanding the number of end-users utilizing a particular technology, and/or expanding the general public's access to new information technologies.

  • Project Feedback: Your thoughts and recommendations on how the TOP program can improve the quality and usefulness of its technical assistance and the quarterly reporting process.

The information in your Quarterly Performance Report will help TOP staff document the steps that individual grant recipients are taking to implement their projects. Within TOP, this information will be used for routine program monitoring, for identifying projects in need of technical assistance, and for identifying potentially promising practices that warrant more intensive study and/or adaption by other projects.

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FINANCIAL REPORTS AND FORMS

During the period that your TOP grant is active, your organization will be required to submit a series of financial reports and forms to the Office of Executive Assistance Management (OEAM). The Financial Assistance Standard Terms and Conditions section of your TOP grant award document contains detailed information regarding these reports and other financial requirements related to your award, as well as instructions on how to request award payments.

The principal financial reports and forms that your organization will be required to submit to OEAM are described below. Links to each of the forms listed below can be found in the Appendix of this Handbook; most of the forms are available online at fillform.gsa.gov.

SF-3881: Automated Clearing House (ACH) Vendor/Miscellaneous Payment Enrollment Form

The first form that your organization will be required to submit to OEAM is the Automated Clearing House (ACH) Vendor/Miscellaneous Payment Enrollment Form (Standard Form 3881 [SF-3881]), which establishes an account into which your grant award payment installments can be electronically transferred. The SF-3881 should be completed and returned to OEAM immediately upon receipt. All grant recipients are required to submit this form.

A link to the SF-3881 form can be found in the Appendix, and is also available online at fillform.gsa.gov

SF-270: Request for Advance or Reimbursement

When your organization wishes to request a payment from your TOP award, you are required to submit a Request for Advance or Reimbursement (Standard Form 270 [SF-270])to OEAM. Such a request can be made no more frequently than monthly, and the request must be limited to the minimum amount necessary to meet immediate disbursement needs. Unless otherwise specified in a Special Award Condition in your grant document, the method of payment for the award will be through a wire transfer of funds directly into your organization's bank account.

A link to a Request for Advance or Reimbursement form can be found in the Appendix, and is also available online at fillform.gsa.gov. Several blank Request for Advance or Reimbursement forms are also included in your grant award document package.

Completed original copies of Request for Advance or Reimbursement forms should be sent to OEAM, not to TOP. All Request for Advance or Reimbursement forms must be submitted in triplicate (one original and two copies).

SF-269: Financial Status Report

Your organization is required to submit a Financial Status Report (Standard Form 269 [SF-269]) to OEAM on a calendar quarter basis for the quarters ending March 31, June 30, September 30, and December 31, or any portion thereof, whether there was financial activity during that period or not. Financial Status Reports are due no later than 30 days following the end of each reporting period.

Your organization is also required to submit a final Financial Status Report to OEAM within 90 days following the expiration of your project's Grant Award Period.

A link to a Financial Status Report form can be found in the Appendix, and is also available online at fillform.gsa.gov. Several blank Financial Status Report forms are also included in your grant award document package.

Completed original copies of Financial Status Reports should be sent to OEAM, not to TOP. All Financial Status Reports must be submitted in triplicate (one original and two copies).

SF-272: Federal Cash Transactions Report

Your organization is also required to submit a Federal Cash Transactions Report (Standard Form 272 [SF-272]) to OEAM that reports on the status of federal funds that have been advanced to your organization. The SF-272 is due fifteen business days following the end of each calendar quarter for awards under $1 million. If your organization has not yet drawn down federal funds on your award, it is not necessary to submit a SF-272.

A link to a Federal Cash Transactions Report form can be found in the Appendix, and is also available online at fillform.gsa.gov. Several blank Federal Cash Transactions Report forms are also included in your grant award document package.

Completed original copies of Federal Cash Transactions Reports should be sent to OEAM, not to TOP. All Federal Cash Transactions Reports must be submitted in triplicate (one original and two copies).

CD-281: Report of Government Property in Possession of Contractor

When your TOP project has been completed, a Report of Government Property in Possession of Contractor (Commerce Department Form 281 [CD-281]) must be submitted to TOP as part of the closeout documentation for the grant award. The CD-281 is an inventory of all equipment acquired under the grant with both federal and non-federal funds.

A link to a Report of Government Property in Possession of Contractor form can be found in the Appendix, and is also available online at www.doc.gov/forms/pdf/cd281fll.pdf.

Should you have questions regarding the preparation of any of these Financial Reports, please contact your OEAM Grants Specialist.

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SPECIAL AWARD CONDITIONS

Your award document may contain one or more Special Award Conditions that require the submission of specific documents to TOP or to OEAM before federal funds can be released to your organization. Special Award Conditions regarding the release of federal funds are generally listed in the first eight pages of your award document. Read them thoroughly, paying particular attention to the date on which each item is due.

Special Award Condition Documentation to be Submitted to TOP

Should you have questions regarding the preparation of any of the items listed below, please contact your TOP Program Officer.

Privacy and Security Safeguards Plan

Your TOP grant award may contain a Special Award Condition that requires your organization to submit a detailed plan describing the policies and technical mechanisms that your group will employ to protect network security and safeguard the privacy of individuals associated with your project. Your organization will be required to submit such a Privacy and Security Safeguards Plan to TOP within 60 days after the award start date.

Your organization's Privacy and Security Safeguards Plan should contain a detailed description of the technical mechanisms your organization plans to employ to safeguard the confidentiality of information and the privacy of any individuals involved with the project, either as end-users or as information providers. Your plan should also discuss specific policies and procedures that your organization plans to use to accomplish this goal, such as non-disclosure agreements, verification procedures, access authorization mechanisms, and the training of staff and end-users regarding the nature of security and privacy issues. In addition, you should indicate how you plan to safeguard the integrity of your own system, and to protect it from viruses, hackers, and other outside threats.

Certification of Non-Federal Matching Funds

Your TOP grant award document may contain a Special Award Condition requiring that your organization submit a letter to TOP within 180 days from the award start date certifying that the entire non-federal share of the matching funds for your project has been secured and is available. No funds from the federal share of your grant award can be released until your organization has provided this certification to TOP.

If your organization is not able to provide this certification, the language of the Non-Federal Matching Funds Special Award Condition states that the grant award "may be terminated." The Non-Federal Matching Funds certification should be in the form of a letter signed by your organization's Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, or other authorized signatory. The non-federal matching funds identified in your letter should be identical in amount to those originally reported as a non-federal match for the project on the SF-424 of your organization's TOP grant application, as negotiated.

Non-Federal Matching Funds are generally of two types:

  • Cash Contributions, which include direct monetary contributions from any non-federal source. Cash contributions are defined in OMB Circular A-110, Subpart A, Sec. 2(f) as "the recipient's cash outlay, including the outlay of money contributed to the recipient by third parties." Salaries for personnel working on a project and paid by the recipient from non-federal funds are considered cash contributions.
  • In-Kind Contributions, which the federal government defines as non-cash donations to a project that may count toward satisfying the non-federal matching requirement of a project's total budget. In general, in-kind contributions might include: 1) contributions of services from individuals, such as professional consultants, engineers, attorneys, programmers, software engineers, systems professionals, etc.; 2) contributions of services from organizations such as telephone companies, network access providers, satellite companies, cable television operators, etc.; and 3) loaned or donated equipment, supplies, and/or building space, including computers, software, office space and equipment, etc.

Third party in-kind contributions may count towards satisfying the non-federal matching requirement of your project budget only in those instances where, if your organization were to pay for them, the payments would be considered allowable costs. You may not count an item or a service as an in-kind contribution simply because it has value; it must be something that is actually used in your project. In general, an item or service may be considered as an in-kind contribution only if it: 1) is an allowable project expense; 2) appears as a projected expenditure in your project budget; and 3) is being donated to your project to save your organization from the cost of purchasing it. In short, an in-kind contribution is something that you would otherwise have to purchase.

More specific information regarding the documentation of in-kind contributions can be found in the Appendix.

Other Types

  • Program Income: All TOP awards contain a Special Award Condition that reads:

"Program income earned during the award period shall be retained by the Recipient and shall be added to funds committed to the award and used for the purposes and under the conditions applicable to the use of award funds."

Program income means gross income earned by a grant recipient that is directly generated by a supported activity or earned as a result of the award. If your organization is assessing fees to outside organizations or individuals for services, such as training, Internet access, or webpage hosting, and the costs of providing those services are included in the project budget (in either the federal or non-federal share), then your project is earning program income.

If your project is earning program income, then your organization, as the recipient, must use the funds for a purpose that is consistent with the purposes of the award. Typically, this would involve using the funds to expand the scope of the project, or for other uses identified at the time of award negotiation. The funds must be obligated during the award period. The use of program income is subject to audit.

All of the responsibilities relating to program income also apply to all subrecipients of an award. For example, if the grant has paid for equipment that your organization transfers to a third party and the third party uses the equipment to provide a service that generates income, then your organization must report the income.

  • Assessing Fees for Grant-Supported Services: All TOP awards will contain a Special Award Condition stating that grant recipients must not use equipment acquired with federal or matching funds to provide services to non-federal outside organizations for a fee that is less than private companies charge for equivalent services. This requirement will extend throughout the period that the Government retains an interest in the equipment.

This Special Award Condition only applies to services provided for a fee. Services provided to outside organizations or to the public free of charge are not affected by this requirement.

Any TOP recipient that is assessing fees for grant-supported services that can also be obtained from private businesses must ensure that the rates charged for those services are no less than what private companies generally charge for "equivalent" services. If you are unsure whether or not your organization is in compliance with these provisions, it is imperative that you contact your TOP Program Officer immediately to discuss the services in question.

This Special Award Condition is in effect for as long as any equipment, such as servers, routers, personal computers, and modems, is used to provide services to outside organizations or to the public for a fee. It applies to TOP awards that have been completed as well as to those that remain active. The equipment in question refers not only to equipment purchased with federal funds, but to all equipment included in the project budget, including that owned by third-parties.

  • Acceptable Use Policies: All TOP awards will contain a provision that the organization submit a detailed plan describing the policies and technical mechanisms that your group will employ to encourage "acceptable use" to online resources, including the Internet. Your Acceptable Use Plan must be submitted to TOP within 60 days after the award start date.

Your organization's Acceptable Use Plan should offer reasonable assurances that safeguards will be in place to ensure that end users (especially minors) do not encounter inappropriate material or dangerous situations while online. The plan may include, but need not be limited to, the use of specialized filtering software, the development of guidelines for acceptable conduct and activities on the network, or a discussion of monitoring steps that will be taken to verify compliance with the organization's policies.

  • Evaluation: All TOP awards will contain a provision that states that the grant recipient agrees to participate in third-party independent evaluations of TOP-funded projects. These evaluations may be conducted either during the life of the project or after the project has closed. These evaluations will be performed at no additional cost to your organization. Participation in these evaluations may take the form of mail or telephone surveys, case study site visit interviews, and/or examination of project records. To ensure full participation of project members, you may also be asked to provide independent evaluators with appropriate names, addresses, and telephone numbers of project staff, partners, and end users. Any reports resulting from the evaluations will be made available to you.


Special Award Condition Documentation to be Submitted to OEAM

Should you have questions regarding any of the items listed below, please contact your OEAM Grants Specialist.

Universal Service Discount Certification

Under the Universal Service Discounts provisions of Section 254 of the Telecommunications Act of 1996, eligible schools, libraries, and public and rural not for-profit health care providers will be allowed discounts on the purchase of all commercially available telecommunications services, Internet access and internal connections.

If your organization or any of your partners and/or subrecipients is eligible, your TOP grant award may contain a Special Award Condition requiring your organization to submit certification to TOP that: 1) your organization will expeditiously apply for and accept any discounts, currently available or for which you may later become eligible, under the Universal Service Discounts provisions of the Act; and that 2) you will advise all partners and/or subrecipients participating in your grant award that they are expected to apply for and to accept any discounts available under the Act.

More information on universal service discounts and eligibility requirements can be found on the Universal Service Administrative Company's website at www.universalservice.org.

Certification of Financial Management System Adequacy

Your TOP Grant Award document may contain a Special Award Condition requiring that your organization submit certification from a Certified Public Accountant to OEAM within 60 days of the award start date that your organization's financial management system is adequate to meet the standards prescribed in OMB Circular A-110.

Other Types of Special Award Condition Documentation

Protecting Human Subjects

This year, TOP determined that every application selected for award involves "human subject research." The federal government defines the term "research" broadly to encompass the study of human behavior, reactions, thought processes as well as tangible study of the human body. "Research" means a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. Federal policy defines a "human subject" as an individual about whom an investigator conducting research obtains:

  • data through intervention or interaction with an individual (e.g., video taping people, observing children using new software, surveying personnel regarding a new delivery of service to a client) or

  • identifiable private information through patient records, a company's customer data, web use logs, etc.

Through Title 15 Part 27 of the Code of Federal Regulations, the Department of Commerce requires that all TOP-sponsored projects ensure protections for any human subjects involved with research or evaluation. For more background on human subject research protections, the Department of Health and Human Services Office of Human Research Protection has created a helpful and easy to read guidebook

Recognizing that many applicants might not have their research and evaluation procedures fully developed by the time of award, TOP created the "Deferral of Review of Use of Human Subjects" Special Award Condition (SAC). This SAC allows you to up to one year to review your research and evaluation procedures and submit to TOP certification that your procedures are either (1) exempt from Human Subject Research Protections or (2) have been reviewed and approved by an Institutional Review Board (IRB). Your TOP Program Officer can help determine if an exemption or IRB approval is needed. In addition, TOP has created a checklist to help guide you through this process.

While you assess your research and evaluation procedures, you are permitted to begin work on other aspects of project implementation. However, as the "Deferral of Review of Use of Human Subjects" SAC indicates, you cannot conduct any research involving human subjects until documentation substantiating an exemption or IRB approval has been submitted to and approved by TOP. Because seeking IRB approval or exemption status may require you to develop research plans, evaluation questions, or survey instruments, TOP allows grantees the ability to allocate resources and spend grant funds on these activities.

If you believe an exemption is warranted, you must first contact your TOP Program Officer and discuss your justification. With respect to TOP projects, exemptions are provided for

  • Research conducted in established or commonly accepted educational settings, involving normal educational practices, such as (i) research on regular and special education instructional strategies, or (ii) research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods.

  • Research involving the use of educational tests cognitive, diagnostic, aptitude, achievement, survey procedures, interview procedures or observation of public behavior, unless: (i) information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; and (ii) any disclosure of the human subjects' responses outside the research could reasonably place the subjects at risk of criminal or civil liability, or be damaging to the subjects' financial standing, employability, or reputation.

  • Research, involving the collection or study of existing data, documents, records, pathological specimens, or diagnostic specimens, if these sources are publicly available, or if the information is recorded by the investigator in such a manner that subjects cannot be identified, directly or through identifiers linked to the subjects.

Once you and your Program Officer have determined that an exemption is appropriate, a sample exemption certification letter will be forwarded to you. Please note: if your project includes members of protected classes (e.g., children, pregnant women, prisoners) as part of your evaluation methodology, even if you are only surveying or collecting data from records, your evaluation MUST be approved by an IRB.

If either you or your Program Officer determines IRB approval is needed, you will need to submit your research procedures, proposed protections, and evaluation instruments to an IRB that has been approved by the U.S. Department of Health and Human Services. If your organization does not have an IRB, many local colleges and universities have approved IRBs that will conduct reviews of your research for a nominal fee (typically less than $900). The Department of Human Services Office of Human Research Protections maintains an updated list of approved Institutional Review Boards (IRB).

Once the IRB has reviewed and approved your research and evaluation procedures, you will need to send two copies of their approval to your TOP Program Officer.

Protecting human subjects is an ongoing activity. For those projects that seek IRB approval, your certification needs to be updated annually. For those projects that are exempt, the exemption is only valid as long as the research on which they are based remains unchanged. In other words, if your project is certified as being exempt from human subject research, and the evaluator decides that they need to alter the research methodology or include subjects from special classes, you would need to contact your TOP Program Officer and resubmit the modified research protocol for either an exemption or perhaps, IRB approval.

Indirect Cost Rate Documentation

Your TOP Grant Award document may contain a Special Award Condition requiring that your organization submit information to your cognizant federal agency(1) to establish an indirect cost rate. Indirect costs are those costs that are incurred in the course of administering a project (for example, the rental of office space), but which are not readily identifiable with direct project goals and outcomes.

Indirect costs cannot be allowable charges against your award unless they have been specifically included as a line item in the approved budget that was incorporated into your award. A proposed indirect cost rate may be incorporated into in an award with the understanding that the grant recipient must seek formal approval for the rate from a cognizant federal agency within 90 days from the award start date.

If your organization is entitled to claim indirect costs and has not previously established an indirect cost rate with a federal agency, your organization will be allowed to draw down indirect costs at your proposed rate for a period of 90 days from the award start date. During this period, your organization will be required to submit documentation to the Department's Office of Inspector General (OIG) or other cognizant federal agency to establish (or renew) such a rate. Such documentation should include an indirect cost proposal and a cost allocation plan. Your organization must provide the OEAM Grants Officer with a copy of your letter of transmittal to the OIG or to your cognizant federal agency.

If the grant recipient organization fails to submit the required documentation to the OIG or other federal agency within the 90 day period, the OEAM Grants Officer is authorized to preclude recovery of any indirect costs under the award.

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PROJECT AMENDMENTS

During the months that your TOP project is active, you may occasionally find that some aspects of your project plan are in need of modification. In such situations, you are required to inform TOP in advance of possible project modifications, to discuss these with your TOP Program Officer, and, in some cases, to formally request and receive prior approvals from TOP and OEAM before such changes can take place. Examples of such situations include instances in which: 1) a project appears to be shifting away from its originally stated objectives and scope; 2) key personnel are about to leave a project; and/or 3) a project budget seems to be in need of re-alignment. In such cases, it may be necessary for you formally request a Project Amendment in order to complete the project.

After you have consulted with your TOP Program Officer and you decide that an Amendment request is warranted, you should prepare an Amendment Request letter and submit it and a copy to TOP at least 30 days before the end of the grant award period.(2) Amendment Requests should not be sought retroactively. The request should be clearly labeled as an Amendment Request, and should not be combined with any other submission. The letter should state clearly what changes your organization wishes to make to the project and the reasons for them. All relevant cost figures must be included. In addition, it is important that your letter contain a statement to the effect that your Amendment Request will not result in any additional cost to the federal government.

All Amendment Requests will be reviewed by TOP and OEAM prior to issuing written approval or denial of your request. If your Amendment Request is approved, the Grants Officer will provide written notification to your organization; if it is denied, the Grants Officer will send a letter notifying you of this fact. Amendment approvals are not considered official until a formal letter of notification has been signed by the Grants Officer.

It is important to remember that no matter what anyone may tell you, including TOP Staff, if you do not receive written approval from the Grants Officer, your request for an amendment is not approved. If your organization decides to purchase items of equipment listed in the Amendment Request prior to receiving written approval, you do so at your own risk. If the Amendment Request is eventually turned down, your organization will have to bear the entire cost of the unauthorized purchase. In addition, if it is learned that the equipment was purchased before written approval was received, the Amendment Request may be denied or the approval rescinded.

Types of Project Amendment Requests Permitted by TOP

Changes in Project Scope or Focus

As TOP grant recipients begin work on their projects, some may find that unanticipated circumstances intervene over time to cause subtle shifts in the overall focus and/or scope of their projects. For example, an organization may come to realize that a technology different from the one proposed in the award document should be used to achieve similar project goals. Another grant recipient might decide that the number of locations served by a project should be increased or decreased, that the number of services provided should be expanded, and/or that the planned project sites should be changed.

Some proposed modifications to the scope or focus of a project are relatively minor and do not require a formal amendment to the grant award. However, in instances where the scope or focus of the project may undergo significant modification, grant recipients are required to request and seek prior written approval before they can undertake such a revision in the program plan. A decision to request a project Scope or Focus Amendment should be made only after you have thoroughly discussed the proposed modifications and the need for such an amendment with your TOP Program Officer. Amendment approvals may not be sought retroactively for changes in project scope or focus.

Grant recipients should be aware that at some point a requested change in project scope or focus represents such a departure from the nature of the project that it cannot be approved by the Grants Officer.

No-Cost Budget Amendments

Occasionally it may be necessary for a TOP grant recipient to request modification of a project's budget in order to complete a project. Such budget amendment requests usually involve the transfer of specific amounts budgeted for one or more categories to one or more other categories in order to absorb unanticipated expenses. As noted in the OMB Circulars, grantees may shift up to 10% of the Total Project Cost (less indirect charges) between and among primary budget categories without seeking approval from the federal government. However, once the 10% threshold is exceeded, or if the grantee believes the line item changes to be significant, the grantee must submit a request for a No-Cost Budget Amendments.

No-Cost Budget Amendment requests must include: (1) a letter explaining the proposed changes, (2) a revised Budget Narrative delineating the proposed modifications, (3) an updated statement of matching funds, and (4) a revised Standard Form 424A (SF-424A), Budget Information - Non-Construction Programs. Sample text of a revised Budget Narrative request can be found in the Appendix. Please note that if the modification alters the grantee's share of the estimated funding, a revised Standard Form 424 (SF-424) is also required.

Before considering any amendment to your project's budget, it is important to remember that your organization was awarded a TOP grant to complete a specific project at an agreed-upon Total Project Cost, with a further understanding that the federal share would not exceed the amount of the specified federal award. Therefore, requests for a No-Cost Budget Amendments cannot seek additional federal funds.

Budget amendments are also required if you would like to pay for an item not listed in your approved budget. In addition, your organization does not have authorization to spend funds to purchase more items than what you listed in your approved budget. For example, if the original approved budget for your project included the purchase of six computers, and these computers actually cost only half of what had been budgeted, your organization does not have authorization to buy additional computers. If your project can be completed for less than the cost that was estimated in the award document, then both your organization and the federal government have saved money. (3)

Any decision to request a No-Cost Budget Amendment should be made only after you have discussed the need for the amendment with your TOP Program Officer. Such requests require the prior written approval of the Grants Officer. No-Cost Budget Amendments cannot be approved retroactively for items purchased or expenses incurred without prior written authorization.

Changes in Key Project Personnel

Your organization must also provide written notification and formally request an amendment for any change in the key person(s) specified in your project's application or award document. While sudden personnel changes cannot always be anticipated in time to seek prior approval from TOP and OEAM, such an amendment is required if the principal administrative oversight and responsibility for a project is going to be shifted from one individual to another within the grant recipient organization. A request for an amendment of this type should be sought as soon as possible, and must be accompanied by a CD-346 — Applicant for Funding Assistance and resume for each key project individual listed.(4)

A Note of Caution

Federal and Non-Federal Cost Share Ratio

In accepting the federal award, your organization is committed to provide the matching funds identified in the approved budget. Therefore, budget amendments that result in a decrease of the non-federal matching share will result in a corresponding decrease in the federal share of the award.

The non-federal share of your award, whether in cash or in-kind contributions, is expected to be paid out at the same general rate as the federal share. Exceptions to this requirement may be granted by the Grants Officer based on sufficient documentation demonstrating previously determined plans for, or later commitment of, cash or in-kind contributions.

Unauthorized Expenditures

Items, services or equipment that do not appear in the award document or has not been the subject of an approved amendment will be removed from the project budget by TOP and OEAM at the time of closeout. If this occurs, your organization may be required to refund federal funds previously paid to your organization.

Outstanding Debts to the Department of Commerce

Please note that if your organization has an outstanding debt with any part of the Department of Commerce that is more than 30 days old, or any known debt with another federal agency, OEAM will not process an Amendment Request until this debt has been satisfied.

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EXTENSIONS OF THE GRANT AWARD PERIOD

The Grant Award Period is the time during which your organization can obligate your federal grant funds to complete your approved project. The Grant Award Period for your TOP grant appears on the first page of your CD-450 award document. All project activities must be completed by the end of the Grant Award Period.

Occasionally a grant recipient organization may consider it necessary to request a one-time extension of a grant award period in order to complete a project. A number of factors beyond the control of the organization may lead them to believe that such an extension is necessary, including slow delivery of equipment from vendors, delays in connecting project sites, unexpected turnover of key project personnel and related causes.

Extension Requests should be made only after you have thoroughly discussed the need for such an extension with your TOP Program Officer. Extension Request letters should be prepared and submitted to TOP at least 30 days before the end of the grant award period. This allows a request to be given full consideration before the Grant Award Period expires. Extension Requests may not be honored retroactively. The request should be clearly labeled as an Extension Request, and should not be combined with a Quarterly Performance Report, an Amendment Request, or any other submission.

Extension Request letters should contain a full explanation of what has happened to make a project extension necessary. Generally TOP will look for causes beyond the grant recipient's control in considering an Extension Request, and it may request supporting documentation to accompany the request. TOP does not look favorably upon requests that appear to result from simple inactivity on the part of the grant recipient organization. The request must include: (1) a statement that the extension does not seek additional federal funding; (2) the length of time requested for the extension; and (3) a revised project timetable.

All Extension Requests will be reviewed by TOP and OEAM prior to issuing written approval or denial of requests. If an Extension Request is approved, the Grants Officer will send an Amendment to Financial Assistance Award (CD-451) Form to the grant recipient organization; if it is denied, the Grants Officer will send a letter notifying the recipient of this fact. Extension approvals are not considered official until the CD-451 Form has been (1) signed by both the Grants Officer and the authorized signatory from a grant recipient organization, and (2) received by the grants officer. No matter what an organization may be told, if it does not receive written approval from OEAM, its request for an extension is not approved.

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PROJECT CLOSEOUT REQUIREMENTS

Your organization is required to provide TOP with full closeout documentation for your project within ninety (90) days following project completion or the expiration of your grant award period, whichever comes first. Closeout documentation includes the following components:

Final Project Report

The final report is your best opportunity to assess the successes, challenges, surprises, and other significant experiences you encountered during your project. The final report should reflect what you learned, what worked, what did not work so well, what you might do differently. Please remember that TOP is a national demonstration program — your experiences are of interest to the program and to communities across the country. As you complete the final report, try to put yourself in the position of a colleague who has not yet had your opportunity, but who would like to embark on a similar project in another community.

Your organization's final project report must be submitted to TOP electronically via the TOP web-based Performance Reporting System (PRS). Prior to the submission of your final quarterly report, you should email your Program Officer alerting him/her that you will not request an extension of the closing date of your award. Your organization will be expected to provide TOP with the following information and data in your final project report:

  • Project Outcomes: Progress that your organization made toward achieving the original long-term outcomes and goals identified for the project, as well as any additional outcomes that the project may have achieved.

  • Project Accomplishments: Information regarding your project's most significant accomplishment or achievement; impacts that your project may have had on the community-at-large; ways in which your project may have changed the way in which end-users perform their jobs and/or carry out other activities; any unanticipated problems that resulted from the project; and the number of individuals who may have directly or indirectly benefitted from TOP-related equipment or resources since the beginning of the project.

  • Partnerships: Your assessment of the overall success of your project's partnerships; factors that may have facilitated or hindered the success of these partnerships; and the extent to which your organization's relationship with your partner organizations may have changed as a result of their participation in your TOP project.

  • Community Impact: Your organization's assessment of the impact that your TOP grant had on your ability to implement your planned initiative or activity.

  • Lessons Learned: Any lessons that your organization learned from this project that might be of interest and use to other organizations attempting similar projects.

  • Project Expansion: Information on efforts to serve additional end-users in locations or organizations beyond those targeted in the TOP proposal.

  • Project Spin-Off Activities: Information, new projects, products, project adaptations that have resulted from the TOP project.

  • Future Plans: Plans that your organization has for the project now that the TOP grant has been completed.

Final Evaluation Report

Your final evaluation report should be mailed directly to TOP. This document should report the results and findings from the study proposed in your grant application. Your discussion should include an analysis of the extent to which the technology proposed and/or employed in your project contributed to the solution of the specific problem(s) defined in your project's proposal. You should also include an analysis of the data on all measures created in your proposal. Please describe fully any changes in your evaluation plan and the rationale for such changes. Please attach all formal evaluation reports, user surveys, focus group results, statistical data, and other evaluation materials that were by-products of the project.

List of Project Expenditures

Closeout documentation should include a complete listing of project-related expenditures by object class category. The list should be organized according to the format of the approved budget contained in the Financial Assistance Award document. Your organization should also provide brief explanations for any aspect of the expenditures that are unusual, or that do not appear on either the originally negotiated project budget or on any subsequently amended budgets. This will greatly facilitate TOP review of your closeout materials. A spreadsheet template is available to assist you.

The total expenditures reported must equal the total project cost reported on the final Financial Status Report (SF 269) submitted to OEAM.

Please also remember that your organization is subject to the auditing requirements described in the Special Terms and Conditions section of your grant award document. Audit requirements are discussed later in this Handbook.

CD-281: Report of Government Property in Possession of Contractor

A Report of Government Property in Possession of Contractor (Commerce Department Form 281 [CD-281]) must be submitted to TOP as part of the closeout documentation for your grant award. The CD-281 is an inventory listing of all equipment that your organization acquired under the grant with both federal and non-federal funds.

Copies of CD-281 forms are included in your grant award packet. A link to a CD-281 form can be found in the Appendix, is also available online at www.doc.gov/forms/pdf/cd281fll.pdf.

Should you have questions regarding the preparation of the CD-281, please contact your Program Officer.

Other Studies, Publications, Reports and/or Other Work Products Generated by the Project

Please include with the closeout documentation copies of any final reports, studies, publicity coverage, letters from the public, awards, etc. that were generated as a result of and that relate to your project. Please do not submit duplicate copies of materials that you previously submitted to TOP along with your Quarterly Performance Reports.

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FACILITATING COMMUNICATION
AMONG TOP GRANT RECIPIENTS

TOP encourages the active exchange of information between grant recipients, program staff, and the public. In addition, TOP staff play a larger role than strictly monitoring projects for compliance with paperwork obligations. The staff actively seek your input and knowledge and, in turn, can provide you with assistance on the issues you face as you implement your project.

TOP Website

TOP also has its own Website at www.ntia.doc.gov/TOP/. The following items on the TOP Website are apt to be of particular interest to TOP grant recipients:

Descriptions of Funded TOP Projects and Contacts

This section contains a description of all TOP projects funded since the program began in 1994, and includes names of project contacts, award amounts and other data pertaining to each project.

TOP's News from the Field

An on-line newsletter that features stories from TOP grant recipients from around the nation. TOP encourages grant recipient contributions to News from the Field. Should you have articles or announcements that you would like to contribute, please contact Judith Sparrow of the TOP staff at jsparrow@ntia.doc.gov.

TOP Update

TOP has a quarterly print newsletter, TOP Update, containing information on the TOP program and projects, as well as articles on various technology applications. Should you have ideas or announcements that you would like to contribute, please contact Judith Sparrow of the TOP staff at jsparrow@ntia.doc.gov

Get Updates

TOP has inaugurated an email list to provide interested parties with updates and other information about the program. The list streamlines the process of communications with grantees. Anyone may join the list by click on Get Updates in the footer of any page on TOP's website.


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AUDIT REQUIREMENTS

All TOP grant recipients are subject to audit requirements contained in Office of Management and Budget (OMB) Circular A-133, revised June 30, 1997. A copy of the A-133 is included in your grant award package.

OMB Circular A-133 requires that non-profit organizations, government agencies, Indian tribes and educational institutions expending more than $300,000 in federal funds during a one-year period conduct an audit in accordance with guidelines outlined in the A-133. These audits are to be performed in one of two ways. A TOP-specific audit may be performed if the organization receives federal funds solely from TOP. If the organization receives funds from more than one federal source during the year that the audit is conducted, an organization-wide audit must be performed.

In general, A-133 requires TOP grant recipients to obtain annual audits(5). Copies of such audits must be provided to each federal agency that provides funds to your organization. The copy of the audit report to be provided to the Department of Commerce should be sent to the following address:

Mr. William F. Bedwell, Jr.
Office of Audits — Regional Audits
Office of Inspector General
U.S. Department of Commerce, Suite 2342
401 West Peachtree Street, NW
Atlanta, GA 30308

A second copy of the audit report should be sent to the Bureau of the Census, which has been designated by OMB as a central clearinghouse. The address is as follows:

Federal Audit Clearinghouse
Bureau of the Census
1201 E. 10th Street
Jeffersonville, IN 47132

All TOP grant recipients are also required to send a copy of the audit transmittal letter to their OEAM Grants Specialist.

We urge you to read and to review the A-133 audit requirements with your accountant.

The Department of Commerce Financial Assistance Standard Terms and Conditions addresses the subject of audits in Section D (page 6). Should you have questions related to audit requirements, please contact your OEAM Grants Specialist.

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APPENDIX

Links to Standard Forms

In addition, the General Services Administration maintains a website (GSA DocNet) that allows you to take selected government form files and fill them out immediately, off of the Internet. The filled form can then be printed or can be saved with the data filled in. Please note that TOP does not provide technical support for either the GSA DocNet site or the Surfer software package used to create and maintain the forms:

SF-3881: Automated Clearing House (ACH) Vendor/Miscellaneous Payment Enrollment Form
SF-270: Request for Advance or Reimbursement
SF-269: Financial Status Report
SF-272: Federal Cash Transactions Report
Click here for form CD-281: Report of Government Property in Possession of Contractor
TOP: Documentation of In-Kind Contributions (example not available online)
Sample Text of Revised Budget Narrative


NOTES

1. A "cognizant federal agency" is the one that provides the largest amount of federal funding to your organization.

2. Even if a No-Cost Budget Amendment request has merit, it is often impossible to process the request and to seek necessary internal approvals prior to the formal expiration date of the award if it is received any later.

3. Funds returned to TOP in this manner may be awarded as grants in subsequent grant rounds.

4. A CD-346 is not required of state and local government entities, including school districts and public libraries, or of accredited colleges and universities.

5. Exceptions are made in the case of some non-profit organizations and some state and local governments in which biennial audits are permitted. See Subpart B, Section __.220 of OMB Circular A-133 (revised June 30, 1997).

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