Attachment6_M-21-20

EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503

March 19, 2021

M-21-20
MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES
FROM:

Robert Fairweather
Acting Director

SUBJECT:

Promoting Public Trust in the Federal Government through Effective
Implementation of the American Rescue Plan Act and Stewardship of the
Taxpayer Resources

The American Rescue Plan Act of 2021 (Pub. L. No. 117-2) (ARP) provides funding for
critical resources to strengthen the backbone of our country, while also responding to the public
health and economic crisis the Nation faces as a result of the COVID-19 pandemic. The ARP
includes funding to set up community vaccination sites nationwide, scale up testing and tracing,
eliminate supply shortage problems, invest in high-quality treatments, and address disparities in
obtaining quality healthcare. The ARP also provides immediate relief to workers and families
bearing the brunt of the public health and economic crisis and critical support to struggling
communities and industries.
This unprecedented and historic crisis requires a swift Government-wide response,
underscoring the need to ensure the public’s trust in how the Federal Government implements
ARP programs and distributes ARP funding. Accountability and transparency of Federal
Government spending and achieving results are necessary for effective stewardship of these
funds. Effective stewardship of taxpayer funds also means supporting all Americans, and as
such, requires advancing racial equity and supporting underserved communities across our
country. Building on recent progress and existing reporting requirements, this Memorandum
supports the requirements outlined in the Executive Orders Advancing Racial Equity and Support
for Underserved Communities Through the Federal Government and Restoring Trust in
Government through Scientific Integrity and Evidence-Based Policymaking.
The Administration is committed to effective implementation and stewardship of ARP
funds. To that end, the Administration will foster accountability and public trust by delivering
effective and equitable relief, while implementing sound financial management of the resources
funding that relief. This includes working with the Pandemic Response Accountability
Committee (PRAC) and agency Inspector Generals to strengthen payment integrity to minimize
the risk of waste, fraud, and abuse; and improving the overall award and administration of
financial assistance programs with an increased focus on human-centered program and service
design to achieve more equitable results.

The Administration will also work with executive departments and agencies (agencies) to
identify ARP programs that—given the nature of the program’s goals and design and the
program’s potential impacts on equitable outcomes—require additional attention (beyond the
overarching financial tracking and reporting requirements herein) to program design, tracking,
and reporting to support agency, Administration, and public understanding of measures such as
trust, equity, and experience that are critical to ensuring the achievement of intended program
outcomes and positive impact for the American public.
Improving Program and Service Design to Achieve More Equity-Oriented Results for Federal
Financial Assistance
To provide the highest integrity in the management of financial assistance, agencies must
apply the requirements of title 2 of the Code of Federal Regulations, Grants and Agreements (2
CFR) to Federal financial assistance funded through the ARP to the maximum extent authorized
by law. This includes the existing requirement in 2 CFR part 25 for financial assistance
recipients to register at SAM.gov. Similarly, as permitted by 2 CFR § 200.101(2), agencies
should apply the provisions of 2 CFR part 200 to grants and cooperative agreements to for-profit
entities, with limited exceptions.
For any new programs authorized and appropriated by the ARP, agencies must submit
their proposed implementation plan of 2 CFR to OMB for approval, by emailing such plans to
ARP.implementation@omb.eop.gov, prior to submitting an Assistance Listing for review. Those
plans should identify whether there are any required exceptions to the application of the
requirements of 2 CFR, given the unique nature and goals of a given program or because the
application of requirements in 2 CFR would pose insurmountable challenges to program
implementation. In the event that OMB disapproves an agency’s implementation plan, that
agency may submit an appeal request to OMB and the White House ARP implementation team,
by emailing their appeal request to ARP.implementation@omb.eop.gov. Such appeals requests
must be made and reviewed prior to program administration and award issuance or, if the need
arises midstream in program implementation, prior to implementation of a new program phase or
issuance of a new tranche of awards. Agencies are discouraged from submitting such appeal
requests until and unless all flexibilities described herein have been considered by the agency.
Agencies should also apply, where appropriate, the flexibilities for recipients in 2 CFR,
including those identified in Appendix 2: Achieving More Equity-Oriented Results for Financial
Assistance, which highlights sections in 2 CFR part 200 that are of particular importance for an
equity-oriented approach to achieving results.
Agencies should also include ARP programs in their ongoing processes for agency equity
and service assessments and agency action plans called for in Executive Order 13985. In
particular, Agency Equity Teams should engage in equity assessments for ARP programs.
Agencies should refer any questions about this part of the ARP program design, implementation,
and assessment process to equity@omb.eop.gov.
Consistent with Executive Order 14008, “Tackling the Climate Crisis at Home and
Abroad,” agencies should also consider, where appropriate, how the implementation of ARP
funding could increase the benefits that flow to disadvantaged communities and invest in
opportunities that help revitalize energy communities.

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Furthermore, agencies should apply, where appropriate, the flexibilities provided in
Appendix 3: Disaster Relief Flexibilities to Reduce Burden for Financial Assistance, as well as
other flexibilities as permitted by law. Agencies should innovate using the flexibilities described
above, consistent with statutory authority and by identifying synergies across programs and
agencies that alleviate burden for recipients.
For all Federal financial assistance, agencies are required to establish detailed and
accurate award descriptions at the time of award. Award descriptions are critical to ensuring
accountability and transparency, as they are a primary means to inform the public of the purpose
of the Federal funding that is distinct from the programmatic level information in the Assistance
Listings.1 Agencies shall establish processes to validate that award descriptions provide
specificity about the award purpose, activities to be performed, deliverables and expected
outcomes, and intended beneficiary(ies) as well as subrecipient activities if known or specified at
the time of award. Within 30 days of issuance of this guidance, agencies shall provide a plan to
validate and improve award descriptions. Thereafter, every quarter close, agencies shall submit a
status update including a summary of the quality of award descriptions. Plans and updates must
be submitted by emailing ARP.implementation@omb.eop.gov.
Consistent with the provisions of the Foundations for Evidence-Based Policymaking Act
of 2018, agencies should use Federal data to assess the effectiveness and equitable delivery of
such programs and suggest improvements.
To reduce recipient reporting burden and consistent with OMB Memorandum M-19-16
Centralized Mission Support Capabilities for the Federal Government (Apr. 26, 2019), agencies
are required to consult with the relevant Quality Service Management Organization (QSMO),
prior to developing new or modernized technology, or considering an existing provider, to
support execution of ARP.
Federal awarding agencies must collect recipient performance reports in a manner that
enables the Federal Government to articulate the outcomes of Federal financial assistance to the
American people. Agencies should consider ways to collect such performance information that
minimizes burden to Federal financial assistance recipients, while still collecting the needed
information, including the use of independent sources of data that may be used to measure
progress. As such in accordance with 2 CFR §§ 200.301 and 200.329, agencies must measure the
recipient's performance to show achievement of program goals and objectives, share lessons
learned, improve program outcomes, and foster adoption of promising practices.
Performance planning, management, and agency reporting for ARP funding should be
incorporated into agencies’ existing organizational performance management routines. Public
reporting should also be integrated with required performance planning and reporting to ensure
alignment with the overarching agency strategic goals and objectives.

1

OMB Memoranda M-18-16, Appendix A to OMB Circular No. A-123, Management of Reporting and Data Integrity Risk (June 6, 2018); M-1824, Strategies to Reduce Grant Recipient Reporting Burden (Sept. 5, 2018); and M-20-21, Implementation Guidance For Supplemental Funding
Provided in Response to the Coronavirus Disease 2019 (COVID-19) (Apr. 10, 2020); and M-21-03, Improvements in Federal Spending
Transparency for Financial Assistance (Nov. 12, 2020).

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Ensuring Robust and Transparent Reporting
In carrying out this Memorandum, agencies will use existing financial transparency and
accountability mechanisms established by OMB Memorandum M-20-21 Implementation
Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019
(COVID-19) (Apr. 10, 2020). As such, agencies must report monthly, including award outlays,
to USAspending.gov for all funding in the ARP and follow existing Government-wide reporting
requirements on USAspending.gov as established by the Federal Funding Accountability and
Transparency Act (FFATA), as amended by the Digital Accountability & Transparency Act
(DATA Act). Agencies are required to ensure that all data required by M-20-21 are reported to
USAspending.gov. Additionally, agencies are also reminded of the direction in M-20-21 to
incorporate reporting of organizational performance on COVID-19 related relief funding into
their established mission performance plans and reports, and review progress regularly as part of
their performance, evidence-building and enterprise risk management routines to the maximum
extent possible.
To help accomplish this reporting, agencies are instructed to expand the usage of the
Disaster and Emergency Funding Code (DEFC) and track ARP funding with a specific DEFC
domain value “V” in their monthly Government-wide Treasury Account Symbol Adjusted Trial
Balance System reporting and to the DATA Act Broker for display on USAspending.gov. In all
instances where agencies cannot use the DEFC attribute to track ARP funds, they should contact
their OMB representative to determine alternative methods of tracking these funds.2
The Federal Assistance Listings3 is the single, authoritative, government-wide
comprehensive source of Federal financial assistance program information, including loans,
produced by the executive branch of the Federal Government. Agencies are required to establish
an assistance listing prior to publicly releasing information regarding the administration of any
new financial assistance program and update existing assistance listings annually.4 Agencies
should pay particular attention to this exercise as an important source of transparency for ARP
funds.
Agencies are reminded of: (1) the subaward reporting requirements located at 2 CFR part
170, Reporting Subawards and Executive Compensation Information; and (2) agencies’
responsibilities to implement processes that support the overall quality of subaward data,
including actions agencies are expected to take when recipients are non-compliant with these
reporting requirements. To emphasize the importance of subaward reporting, OMB included this
topic in the 2020 Compliance Supplement Addendum as one of the areas auditors are required to
review in COVID-19 grants and cooperative agreement programs. OMB will also include this
topic as topic a requirement for all financial assistance programs reviewed under the Single
Audit requirements in the 2021 Compliance Supplement.
Agencies that have determined they are subject to the DATA Act reporting must maintain
a Data Quality Plan which includes controls to manage risks to reporting objectives in
accordance with OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk
2

Certain provisions of the ARP, such as those involving taxes, receipts, and entitlements, may require alternative methods of reporting. OMB has
worked with agencies to develop alternate reporting methods for funds related to the CARES Act (Pub. L. No. 116-136) and the Consolidated
Appropriations Act of 2021 (Pub. L. No. 116-260).
3
Formerly referred to as the Catalog of Federal Domestic Assistance (CFDA).
4
2 CFR §200.203, Requirement to provide public notice of Federal financial assistance programs

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Management and Internal Control. Consistent with OMB Memoranda M-18-08 Guidance on
Disaster and Emergency Fund Tracking and M-20-21 agencies must consider the following data
elements in their Data Quality Plan pertaining to their testing plan and identification of high-risk
reported data: plain English financial assistance award descriptions,5 DEF Code, and award
outlays. Agencies are further reminded that reporting on loans is an essential part of providing
transparency for Federal spending, and agencies for which loans are a significant part of their
portfolio should carefully consider whether their compliance with existing policy should be
included in their Data Quality Plans.
Additional guidance providing further detail and covering a fuller range of items will be
issued. Questions about this memorandum or the guidance generally can be addressed to your
agency’s OMB counterparts or to ARP.implementation@omb.eop.gov.
Thank you for your attention to these matters.
Appendices:
1- Management of Payment Integrity Risks
2- Achieving More Equity-Oriented Results for Financial Assistance
3- Disaster Relief Flexibilities to Reduce Burden for Financial Assistance

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Additional guidance for financial assistance award descriptions can be found in OMB Memorandum M-21-03, Improvements in Federal
Spending Transparency in Financial Assistance (Nov. 12, 2020).

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Appendix 1: Management of Payment Integrity Risks Related to American Rescue Plan Funding
The Payment Integrity Information Act of 2019 (PIIA) and OMB Memorandum M-2119, Transmittal of Appendix C to OMB Circular A-123, Requirements for Payment Integrity
Improvement (Mar. 5, 2021), establish the framework for assessing payment integrity risks and
developing corrective actions to mitigate those risks. When conducting an improper payment
risk assessment for programs receiving ARP funding, agencies should ensure that in addition to
providing proper consideration to the relevant factors referenced in M-21-19 and PIIA, they have
also considered the impact that the following risk factors have on the program’s payment
integrity and whether those factors are significant enough to warrant the implementation of
additional payment integrity risk mitigation strategies prior to disbursing funds, such as:
• New Legal Provisions;
• Change to Existing Program Eligibility Rules;
• Increased Volume of Program Applications; and
• Limitations in Resources Relative to Volume of Applications or Funding.
Moreover, certain risks listed in PIIA will likely be more salient for ARP relief,
including, “whether the program or activity reviewed is new to the executive agency,” “the
volume of payments made through the program or activity reviewed,” and “recent major changes
in program funding, authorities, practices, or procedures.” Generally, it is the agencies’
responsibility to assess their existing internal controls for the payment integrity of current
programs and to design controls for new programs to mitigate payment integrity risks. In
making these decisions, agencies should leverage existing resources, including the Department
of the Treasury’s Do Not Pay Portal and Payment Integrity Center of Excellence6 and similar
federal entities or databases. Agencies should consider controls for checking any new eligibility
requirements. Agencies should also work with their Inspectors General to identify other areas of
risk and support. In addition, agencies should consider different strategies that can be
implemented in the short term to mitigate payment integrity risks, such as increased automation,
behavioral influence, internal process or policy change, and predictive analytics. Agencies must
continue to report pursuant to PIIA their improper payments on paymentaccuracy.gov. Finally,
agencies must balance financial management and programmatic goals, including speed of
delivery, burden on beneficiaries, and other program attributes that impact racial equity and
support for underserved communities, when considering changes to internal controls. Agencies
should advance racial equity by administering programs fairly and equitably.
OMB anticipates continued collaboration with the PRAC to include joint
communications on issues related to ARP relief that will raise awareness on specific challenges
and opportunities for payment integrity.

6

U.S. Department of Treasury, Payment Integrity Center of Excellence, https://www.fiscal.treasury.gov/payment-integrity-center/ (March 18,
2021); U.S. Department of Treasury, Do Not Pay, https://www.fiscal.treasury.gov/DNP/ (March 18, 2021).

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Appendix 2 - Achieving More Equity-Oriented Results for Financial Assistance
Consistent with the requirements in 2 CFR part 200 Uniform Administrative
Requirements, Cost Principles, And Audit Requirements for Federal Awards, Federal awarding
agencies are required to administer programs in a manner that promotes fair and equitable
administration of financial assistance and takes a risk-based, data-driven approach that balances
compliance requirements with demonstrating successful results. OMB also reminds agencies of
the following requirements that are of particular importance for administering crisis relief funds.
Agencies must apply these requirements to all types of Federal financial assistance funded
through the ARP to the maximum extent authorized by law. For all new programs, agencies are
required to submit their proposed implementation of 2 CFR part 200 to OMB for approval prior
to program administration and award issuance. For more resources, agencies may leverage
Managing for Results: The Performance Management Playbook for Federal Awarding Agencies
and other items available at https://www.cfo.gov/financial-assistance.
I. Program Planning and Design: As reflected in 2 CFR § 200.202, a program must be designed
with clear goals and objectives that facilitate the delivery of meaningful results. The
Administration expects agencies to set a limited number of ambitious, but achievable goals that
encourage innovation and adoption of evidence-based strategies. Well-designed programs, with
a focus on equity implications, represent a critical component of an agency’s implementation
strategies and will contribute to longer-term outcomes responsive to the current crisis. Federal
awarding agencies are encouraged to review resources that focus on program design. (2 CFR §
200.202)
II. Public Availability of Notice of Funding Opportunities (NOFOs): Pursuant to 2 CFR §
200.203, for discretionary grants and cooperative agreements that are competed, agencies are
required to post NOFOs to the OMB designated website Grants.gov. Further, to leverage the
information in Grants.gov for data analytics, agencies must post the full text of the NOFO as an
attachment in the “Full Announcement” folder on the “Related Documents” tab in addition to
completing the synopsis.
III. Performance Reporting: As required by 2 CFR §§ 200.301 and 200.329, Federal awarding
agencies must measure the recipient’s performance to show achievement of program goals and
objectives, share lessons learned, improve program outcomes, and foster adoption of promising
practices. Agencies are strongly encouraged to focus their Federal agency performance reporting
on the intended program outcomes to produce value to the American taxpayer. Federal awarding
agencies must collect performance reports in a manner that enables the Federal government to
articulate the outcomes of financial assistance funding to the American people. Finally, Federal
awarding agencies must consider the appropriate interval of performance reporting to best inform
improvements in program outcomes and productivity as establishing reporting requirements.
IV. Risk Management: Agencies are required to maximize use of risk management approaches
to direct technical assistance and administrative relief for crisis response to funding recipients.
Appropriately focusing on a risk-based approach emphasizes the importance of program
performance outcome measures and equitable economic recovery effectiveness for working
families, communities, and small businesses. Agencies may adjust terms and conditions of
awards based on risk of achieving the intended outcomes. (2 CFR § 200.206)

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V. Case-by-Case Exceptions: 2 CFR § 200.102 allows Federal awarding agencies to grant caseby-case exceptions for individual Federal awards, except where otherwise required by law or
where OMB or other approval is expressly required. Federal awarding agencies are encouraged
to use this provision as necessary when the conditions warrant an exception to support the
implementation of crisis relief funds.
VI. Innovative Funding Approaches: Agencies are encouraged to take, to the extent authorized
by law, innovative administrative approaches to increase efficiency and effectiveness across
programs (e.g., braiding and blending funds). These approaches may be employed across
multiple programs and agencies to better reach under-served communities and alleviate burden
on recipients. (See e.g., 2 CFR §§ 200.102, 200.201(b), and 200.333)
VII. Procurement of Common or Shared Goods and Services (including Information
Technology): As reflected in 2 CFR § 200.318, Federal awarding agencies should encourage
recipients to enter into State and local intergovernmental agreements or inter-entity agreements,
where appropriate for procurement or use of common or shared goods and services.
VIII. Financial Assistance Awards to For-Profit Organizations: For purposes of ARP
implementation, Federal awarding agencies are expected to follow the requirements as directed
by OMB in 2 CFR part 200 for financial assistance awards to for-profit organizations to the
maximum extent authorized by law. This Uniform Guidance, as adopted by the agencies,
provides requirements for all federal awards from program design to closeout and includes audit
requirements under the Single Audit Act of 1996. As consistent with the policy for all Federal
awards, fee and profits are not allowable. Agencies may consider deviations in the following
areas:
• Cost sharing or matching
• Equipment
• Intellectual Property
• Indirect costs
• Audits (agencies should consider whether Single Audit or some other audit is
most appropriate)
Federal awarding agencies must develop a set of standard terms and conditions that are clear and
transparent for awards to for-profit organizations.
IX. Other Types of Federal Financial Assistance: Agencies should apply the requirements of 2
CFR part 200 to all types of financial assistance awards funded through the ARP, including the
application of those provisions of that guidance that would typically apply only to grants and
cooperative agreements. This includes considering a general application with deviations from
specific provisions (such as elimination of accounting of costs for a fixed price award). The
deviations must be clearly communicated to applicants and recipients in the terms and conditions
of the award.
X. Use of Single Audit to drive accountability and transparency: Non-Federal entities (States,
local governments, tribes, and non-profit organizations) with $750,000 or more in federal
expenditures are required by the Single Audit Act Amendments of 1996 (Single Audit) and 2
CFR Subpart F to have an annual audit of their Federal awards (e.g., grant and loan
programs). Consistent with 2 CFR Subpart F § 200.519, agencies must perform a risk analysis
of ARP programs and request OMB to designate any higher risk programs as Single Audit major
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programs, i.e., programs which must be tested in a particular year. OMB will use the 2 CFR
Subpart F Compliance Supplement to notify auditors of compliance requirements that should be
tested for ARP programs. Consistent with existing policy, Single Audit reports, along with their
audit findings, filed with the Federal Audit Clearinghouse (FAC) will be made publicly available
with limited exceptions.

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Appendix 3 - Disaster Relief Flexibilities to Reduce Burden for Financial Assistance
Pursuant to 2 CFR § 200.201, OMB in order to provide administrative relief, OMB is
allowing Federal awarding agencies the authority to grant the following exceptions to recipients
affected by the pandemic as they deem appropriate and to the extent permitted by law. These
exceptions apply not only to recipients with COVID-19 related Federal financial assistance
awards, but also to recipients with assistance awards not related to COVID-19. Federal awarding
agencies must specifically consider exceptions that can advance racial equity and support for
underserved communities. Further, Federal awarding agencies are required to maintain records of
particular exceptions provided to recipients.
I. Flexibility with SAM registration/recertification: Federal awarding agencies may relax the
timing of the requirement for active SAM registration at time of application in order to
expeditiously issue funding. At the time of award, the requirements of 2 CFR § 200.206, Federal
awarding agency review of risk posed by applicants, continue to apply. Current registrants in
SAM with active registrations expiring between April 1, 2021 and September 30, 2021 will
automatically be afforded a one-time extension of 180 days. (2 CFR § 25.110)
II. Waiver for NOFO Publication: Awarding agencies may publish emergency and competitive
NOFOs for grants and cooperative agreements for less than 30 days without separately justifying
shortening the timeframe for each NOFO. Awarding agencies are still required to document and
track NOFOs published for less than 30 days under this emergency waiver. (2 CFR § 200.204)
III. Pre-award costs: Awarding agencies may allow necessary pre-award costs that are incurred:
(i) from March 15, 2021 through the Public Health Emergency Period; and (ii) prior to the
effective date of a Federal award. (2 CFR § 200.210, 2 CFR § 200.458)
IV. No-cost extensions on expiring awards: To the extent permitted by law, awarding agencies
may extend awards that were active as of March 31, 2021 and scheduled to expire prior or up to
December 31, 2021, automatically at no cost for a period of up to 12 months. This will allow
time for recipient assessments, the resumption of many individual projects, and a report on
program progress and financial status to agency staff. Project-specific financial and performance
reports will be due 90 days following the end date of the extension. Awarding agencies will
examine the need to extend other project reporting as the need arises. (2 CFR § 200.309)
V. Abbreviated non-competitive continuation requests: For non-competitive continuation
requests scheduled between April 1, 2021 and December 31, 2021, awarding agencies may accept
a brief statement from recipients to verify that they are in a position to: (i) resume or restore their
project activities and (ii) accept a planned continuation award. Agencies must post any specific
instructions on their website. Agencies must examine the need to extend this approach on
subsequent continuation award start dates as recipients have an opportunity to assess the situation.
(2 CFR § 200.309)
VI. Waivers from prior approval requirements: Awarding agencies are authorized to waive prior
approval requirements as necessary to effectively address the response. All costs charged to
Federal awards must be consistent with Federal cost policy guidelines and the terms of the award,
except where specified in this memorandum. (2 CFR § 200.407)

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VII. Exemption of certain procurement requirements: Awarding agencies may waive the
procurement requirements contained in 2 CFR § 200.319(b) regarding geographical preferences
and 2 CFR § 200.321 regarding contracting small and minority businesses, women's business
enterprises, and labor surplus area firms. Awarding agencies must require recipients to maintain
appropriate records and documentation to support the charges against the Federal awards. (2 CFR
§ 200.319(b), 2 CFR § 200.321)
VIII. Extension of financial and other reporting: Awarding agencies may allow recipients to
delay submission of financial, performance and other reports up to three months beyond the
normal due date. If an agency allows such a delay, recipients may continue to draw down Federal
funds without the timely submission of these reports. These reports, however, must be submitted
at the end of the extension period. In addition, awarding agencies may waive the requirement for
recipients to notify the agency of problems, delays, or adverse conditions related to COVID-19 on
an award by award basis. (2 CFR § 200.328, 2 CFR § 200.329, 2 CFR § 200.329(e)(1))
IX. Extension of Single Audit submission: Awarding agencies, in their capacity as cognizant or
oversight agencies for audit, should allow recipients and subrecipients that have not yet filed their
single audits with the Federal Audit Clearinghouse as of the date of the issuance of this
memorandum that have fiscal year-ends through June 30, 2021, to delay the completion and
submission of the Single Audit reporting package, as required under Subpart F of 2 CFR §
200.501 to six months beyond the normal due date. No further action by awarding agencies is
required to enact this extension. This extension does not require individual recipients and
subrecipients to seek approval for the extension by the cognizant or oversight agency for audit;
however, recipients and subrecipients should maintain documentation of the reason for the
delayed filing. Recipients and subrecipients taking advantage of this extension would still qualify
as a "low-risk auditee" under the criteria of 2 CFR § 200.520(a). (2 CFR § 200.501)
X. Flexibility with application deadlines: Awarding agencies may provide flexibility with regard
to the submission of competing applications in response to specific announcements, as well as
unsolicited applications, presuming these exceptions do not negatively impact underserved
communities. As appropriate, agencies should list specific guidance on their websites and
provide a point of contact for an agency program official. (2 CFR § 200.204)
XI. Extension of closeout: Awarding agencies may allow the grantee to delay submission of any
pending financial, performance and other reports required by the terms of the award for the
closeout of expired projects, provided that proper notice about the reporting delay is given by the
grantee to the agency. This delay in submitting closeout reports may not exceed one year after the
award expires. Upon receipt of all final reports, awarding agencies have six months to close out
the award. (Guidance to Federal Agencies and Recipients) (2 CFR § 200.344)
XII. Flexibility for the Management requirement related to Physical Inventories: Awarding
agencies may provide grantees up to a 12-month extension for the biennial physical inventory of
equipment purchased under a Federal award. (2 CFR § 200.313 (d) (2))

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