NHPRC Requirements

NHPRC Requirements

Federal rules are supplemented by the Commission's own requirements and suggestions for grant administration.

When will the terms of the grant be specified?

• The official grant instrument is a Notice of Award from the Commission's chair to the project director. This form and its attachments and references specify the terms of the grant.
  
  
• The Commission staff notifies project directors informally of awards soon after the Commission recommends the grants.

Who administers the grant?

• Responsibility for administering the grant is shared by the project director and the institution disbursing the grant funds.
  
  
• Grant recipients are generally required to submit annual financial status reports and semiannual or annual narrative progress reports (depending on the nature of the project), as well as final reports at the conclusion of the grant period.
  
  
• Ongoing documentary editing projects are subject to slightly different requirements, explained in the Narrative Reporting section.

When will the grant begin?

• The grant period begins and ends on the dates specified in the official grant instrument. Grant periods must begin on the first day of a month and end on the last day of a month.
  
  
• The grant period may begin any time after the Commission makes its determination; however, please allow at least 3 weeks lead time between the date of the Commission meeting and the start of the grant period.

How soon, and for how long, can grant funds be used?

• Grant recipients may not use grant funds to pay expenses incurred prior to the official starting date of the grant period or count any funds expended before the start of the grant period in the cost-sharing or matching categories, except in unusual circumstances, and only with prior approval.
  
  
• All funds must be obligated (by contract or purchase order) by the ending date of the grant period. All bills and invoices must be paid within the 90 days following the end of the grant period.
  
  
• The final financial report and request for payment must be received by the end of the 90-day period. Any grant funds not requested by that time may be forfeited. Also, all financial and narrative reports must be up-to-date in order to have payments processed.

How are grant funds made available?

• The Notice of Award will be accompanied by instructions that explain how to receive grant funds and how to manage them.
  
  
• All payments are made by electronic funds transfer into designated accounts. Please feel free to consult the Commission staff if you require more information.

Does receiving an NHPRC grant affect recruitment of project personnel?

• Yes. Qualifications of professional personnel should conform to the standards of the job descriptions included in the proposal. Grant recipients should conduct the widest possible recruitment effort for personnel not specified by name in the grant proposal.
  
  
• Professional positions should ordinarily be advertised in such periodicals as the Chronicle of Higher Education, the American Historical Association's Perspectives, the Organization of American Historians Newsletter, the Association for Documentary Editing's Documentary Editing, the Society of American Archivists' Archival Outlook , and the American Association of State and Local History's Dispatch. State, regional, and subject-oriented media are also appropriate. Electronic postings are encouraged.

What are the legal requirements for keeping track of grant funds?

• Grant recipients must keep financial records for each grant in accordance with generally accepted accounting practices. In other words, you must be able to show how you spent the money in a clearly understandable manner. These and other program records are subject to inspection and audit by authorized Federal agencies at all reasonable times during the grant period and for 3 years thereafter.
  
  
• Federal regulations specify standards for grant recipients' financial management systems. State, local, and federally recognized Native American tribal governments may use their own financial management systems, as authorized by state law, as well as their own procedures, as long as the system is able to provide the required financial reports and to trace funds to a level of expenditure sufficient to show that grant funds have been spent in compliance with applicable laws and regulations (see 36 CFR 1207).
  
  
• For institutions of higher learning, hospitals, and other nonprofit organizations, financial systems must meet seven key financial management standards. In very general terms, these grant recipients must be able to demonstrate accounting, budgetary and internal controls, cash management, reporting capability, cost allowable determination, and source documentation (see 36 CFR 1210).

Are grant funds subject to audits?

• Yes. Grant recipients must comply with the audit requirements set forth in OMB Circular A-133, "Audits of State, Local Governments, and Non-Profit Institutions." Generally, grant recipients that expend $500,000 or more in a year in Federal awards must have a single or program-specific audit conducted for that year. A reasonable portion of grant funds, as defined in the OMB circular, may be used to comply with audit requirements. The Commission prefers that grant recipients assume such costs as cost sharing.

Are there rules that affect procurements?

• Yes. Please see 36 CFR 1207 or 1210, as applicable.

What if there is a problem with a contractor?

• The Commission will not be responsible for the settlement of contractual or administrative disputes relating to procurements.

Are there any limitations on the awarding of subgrants or contracts?

• Yes. Grant and subgrant recipients must not make any award (subgrant or contract) to any party that is debarred, suspended, or otherwise excluded from, or ineligible for participation in Federal assistance programs.
  
  
• The General Services Administration publishes a monthly List of Parties Excluded from Federal Procurement or Nonprocurement Programs that grant recipients should consult before awarding a sub-grant or contract.
  
  
• The List is available:
  
  
  1. By subscription from the Government Printing Office
     • Telephone 202-512-1800
       Request Reference Stock Number 722-002-00000-8
       
       
  2. Electronically:
     • Online at https://www.epls.gov/
     • Electronic Bulletin Board
       Dial 202-219-0132 and use settings N-8-1-F

May an extension of the grant period be requested?

• Yes. An extension of the grant period may be requested if it is absolutely necessary to conclude the project. It is necessary to request the extension prior to the time the grant period ends, but not more than 2 months before that scheduled end. All financial and narrative reports must be up to date before an extension will be considered. No more than two extensions will normally be granted.
  
  
• The request for an extension must be signed by the grant-receiving institution's authorized representative as indicated on the grant application form (SF 424).

What if there are unexpected expenses in a budget category?

• Amounts allocated to existing budget lines for both grant funds and cost sharing may be adjusted to meet unanticipated program needs. Grant funds may be transferred among existing NHPRC-funded direct cost categories that appear in the final project budget approved by the Commission at the time of the grant award. Cost-sharing funds may also be shifted among existing cost-sharing categories.
  
  
• For grants in which the NHPRC's award is less than $100,000, grant recipients may make these transfers without NHPRC approval. When Commission grant awards are $100,000 or more, grant recipients must obtain prior approval from the NHPRC when cumulative transfers among direct cost categories total more than 10 percent of the total project budget (i.e., grant funds plus other funds).
  
  
• In addition, the Executive Director of the Commission, or the Executive Director's designee, may approve the use of NHPRC grant funds for new cost categories for which Commission funds were not provided in the final approved budget where such action seems appropriate for the fulfillment of the original purposes of the grant, and where the amount of funds involved does not exceed 10 percent of the amount of the award.
  
  

What types of project changes require NHPRC approval?

• Prior written approval must be obtained from the Commission for changes in all cases, including:
  • Revision of the scope or objectives of the project.
  • Change of the project director or other key project personnel who are specifically named in the grant application or award or related correspondence.
  • Contracting out, subgranting, or otherwise obtaining the services of a third party to perform activities central to the purposes of the grant, unless specified in the grant proposal.
    
    
• You must submit all requests for changes in the form of a letter signed by the grant-receiving institution's authorized representative. A written response signed by the Commission's Executive Director, or the Executive Director's designee, will constitute approval for the change.