That depends on the statutory authority of the other Federal grant program. As provided in 2 CFR 200.306(b)(5), funds from one Federal grant may not be used as cost-share for another Federal grant unless a federal statute (e.g., HUD’s Community Development Block Grant statute) provides otherwise. Section 138 of the Clean Air Act, the statutory authority for the CCGP, does not authorize the use of CCGP grant funding as cost share for other Federal grants.
No, EPA will award and issue the grant simultaneously. Please note the Readiness, Feasibility, and other requirements in the NOFO.
Yes, you may be able to use CCGP funding as part of a larger project that is receiving resources from other sources. However, you must have effective accounting controls in place to ensure that the same costs are not charged to two different funding sources as required by 2 CFR 200.403(f) and 2 CFR 200.405(a).
EPA will pay recipients under a draw-down system unless the recipient qualifies for an initial lump sum payment as a working capital advance under 2 CFR 200.305(b)(4). Working capital advances, however, will not be made in the entire amount of the award but will only “...cover [the recipient’s] estimated disbursement needs for an initial period generally geared to the [recipient’s] disbursing cycle. Thereafter, [EPA] must reimburse the [recipient] for its actual cash disbursements” as provided in that regulation.
Here is a summary of the draw-down requirements from EPA’s General Term and Conditionss, “Automated Standard Application Payments (ASAP) and Proper Payment Draw Down.”
“Recipients must enroll in the Automated Standard Application for Payments (ASAP) system to draw down funds. Payments made to recipients through ASAP are virtually instantaneous— typically the same business day. Recipients must draw down funds based on actual costs incurred (“immediate cash requirements”) rather than in a single draw at the beginning of the grant or multiple lump sum draws based on estimated costs in order to comply with 2 CFR 200.305(b). Recipients do not have to pay employees, contractors and subrecipients before obtaining payment from ASAP but must disburse the funds for the incurred costs within 5 working days of receiving the ASAP payment subject to a 5% of the amount of payment or $1,000 cushion for calculation errors. EPA’s Award Official may make exceptions to the 5-business day disbursement basis based on documented circumstances that prevent the recipient from complying with that requirement. Recipients must return excess funds through ASAP.”
No. There is no cost-sharing or matching requirement under the NOFO.
No, the entire award amount does not need to flow down to subrecipients
As stated in Section III.B of the NOFO: “If selected for award, the Lead Applicant will become the grantee, operating as a pass-through entity for purposes of 2 CFR Part 200 and the EPA Subaward Policy, and taking responsibility for making subawards to Collaborating Entities.” The Lead Applicant will describe its process and capacity to make subawards in the application, including in the required Partnership Agreement among the Statutory Partners.