FAA
Airports
Airport Improvement Program (AIP) Grant Payment and
Sponsor Financial Reporting Policy
Office of Airports
Federal Aviation Administration
October 2020
AIP Grant Payment and
Sponsor Financial Reporting Policy
Issued: October, 2020 Page 2 of 47
Airports
Table of Contents
Section 1: Applicability .................................................................................................... 3
Section 2: Payment Request Method .............................................................................. 3
Section 3: Payment Request Frequency ......................................................................... 4
Section 4: Authorized Payment Requesters .................................................................... 4
Section 5: Payment Standards and Supporting Documentation Requirements .............. 4
Section 6: Review and Approval of Payment Requests .................................................. 8
Section 7: Improper Payments ...................................................................................... 15
Section 8: Award Funds Status at Closeout .................................................................. 15
Section 9: Financial Reporting ...................................................................................... 17
Appendix A. System Waiver Request Form .................................................................. 19
Appendix B. Oversight Area Risk Documentation Form ................................................ 22
Appendix C. Example of Invoice Summary ................................................................... 28
Appendix D. Example of Contract Pay Request and Line Item Summary ..................... 31
Appendix E. Example of Sponsor Certification Letter and Supporting Documentation to
Support Pay Requests for Elevated Sponsors ........................................... 36
Appendix F. Hierarchy Assignment Form ...................................................................... 40
Appendix G. Approval Hierarchy Request Form ........................................................... 41
Appendix H. SF 425 Form ............................................................................................. 42
Appendix I. SF 270 Form .............................................................................................. 44
Appendix J. SF 271 Form .............................................................................................. 46
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Sponsor Financial Reporting Policy
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Section 1: Applicability
This policy pertains to the requirements for submitting, reviewing, and approving grant
payment requests, as well as financial reporting requirements for sponsors. Unless
otherwise noted, the requirements within this policy apply uniformly to all grant
sponsors, including those States participating in the State Block Grant Program
(SBGP). This policy is effective on the date grant payment activities are transitioned into
the Delphi eInvoicing system. Delphi eInvoiceing training (PowerPoint) is available
online at https://www.faa.gov/airports/aip/grant_payments/media/Delphi-eInvoicing-
External-Training.pptm.
Section 2: Payment Request Method
U.S. Department of Transportation (DOT) Electronic Grants Payment System
All sponsors must submit their grant payment requests electronically through the DOT
Electronic Grants Payment System, Delphi eInvoicing. All grant sponsor users must
complete an e-Authentication process to acquire system access and maintain an active
registration in Delphi eInvoicing to ensure timely payment. Delphi eInvoicing Training
Materials are available from DOT at https://www.transportation.gov/policy-
initiatives/delphi-einvoicing-system-training-materials.
U.S. DOT Electronic Grants Payment System Waiver Policy
On a very limited basis the DOT’s Office of Financial Management may issue sponsors
a system waiver that permits payment requests be submitted by hard copy rather than
electronically through Delphi eInvoicing. All sponsors requesting a system waiver must
first consult with their Regional Office /Airports District Office (RO/ADO) before
submitting their request. All sponsors seeking a system waiver must complete the
Waiver Request Form (Appendix A) and follow the instructions on the form for submittal.
The Federal Aviation Administration (FAA) will only make waiver recommendations to
the DOT for sponsors that can clearly demonstrate they are unable to use or access the
internet to register and enter payment requests through Delphi eInvoicing. Sponsors
must provide a copy of their Waiver Request Form to their RO/ADO before submittal for
review. All requests will be reviewed by the DOT’s Office of Financial Management and
sponsors will receive a written response confirming or denying their request from the
DOT.
Sponsors issued a system waiver must submit all payment requests via hard paper
copy to their appropriate RO/ADO for review. Payment requests must include the
completed SF-271, Outlay Report and Request for Reimbursement for Construction
Programs, or for non-construction projects, the SF-270, Request for Advance or
Reimbursement. An approved equivalent form may also be used in place of these
forms. Sponsors must also include any other required supporting documentation
associated with their grant payment risk level, as outlined in Table 2: Grant Payment
Supporting Documentation Requirements (Table 2). All sponsors issued a system
waiver are still expected to meet the payment frequency requirements outlined in
Section 3.
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Sponsor Financial Reporting Policy
Issued: October, 2020 Page 4 of 47
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Section 3: Payment Request Frequency
Sponsors must initiate a payment request for activities conducted in accordance with
project progress and receipt of contractor invoices. This will typically be monthly but
may vary depending on the type of project. It should be noted that continued grant
payment inactivity, defined as no drawdowns over a 12 month period, can be cause for
termination of a grant agreement. For further guidance on grant termination policies and
procedures please refer to the most current version of FAA Order 5100.38 (Airport
Improvement Program) and FAA Order 5190.6 (Airport Compliance Manual).
Section 4: Authorized Payment Requesters
Only those users that have successfully completed the eAuthentication process and
have been granted access to Delphi eInvoicing may submit payment requests.
Sponsors are not limited in the number of users they designate as authorized to request
payments on their behalf. Sponsors may assign a designee to prepare and save
payment requests on their behalf in Delphi eInvoicing; however, sponsors must review
any designee prepared payment requests for accuracy before the sponsor submits a
payment request. It is the responsibility of the sponsor to ensure all payment requests
are accurate and meet all grant payment requirements.
Section 5: Payment Standards and Supporting Documentation Requirements
Payment Standards
All payment requests must meet the standards described in 2 CFR §§ 200.302 and 305,
and the Cash Management Improvement Act of 1990 (CMIA). Under 2 CFR § 200.302 a
sponsor’s financial management system must be able to –
• Document compliance with Federal statutes, regulations and terms and
conditions of the award;
• Track revenues and expenditures for each individual Federal award; and
• Meet Federal reporting requirements as described in 2 CFR §§ 200.327
and 328.
The intent of 2 CFR § 200.305 and the CMIA is to minimize the time between the
transfer of funds to the States and the payout for program expenses. The CMIA also
strives to ensure that Federal funds are available when requested and to assess an
interest liability to the Federal government and/or the States to compensate for the lost
value of funds. However, a sponsor may earn and retain up to $500.00 per year in
interest income to cover its administrative expenses. Any interest earned from Federal
fund deposits in excess of $500.00 annually must be returned to the Federal
government. See 2 CFR § 200.305(b)(9) for remittance guidance details. AIP has
developed a training resource to help with implementation of the payment policy. To
access these materials please visit the AIP payment policy training web site link at:
https://www.faa.gov/airports/aip/grant_payments/.
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Sponsor Financial Reporting Policy
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Supporting Documentation Requirements
All sponsors are required to provide supporting documentation for all payment requests.
Supporting documentation must be uploaded electronically as attachments to the
payment request in Delphi eInvoicing. The sponsor’s grant payment risk level will be
used to determine the supporting documentation required to accompany their payment
requests.
It is the FAA’s policy that payment requests will represent the Federal share of incurred
costs for each eligible invoice amount, and the grantee must provide supporting
documentation for the full eligible amount to justify the amount of the payment
requested. Any required cost-share amount must be included in the invoice(s) and
payment request, and both the Federal and non-Federal shares must be shown as
separate components of the total. The Federal reimbursable amount (requested
amount) must be calculated by applying the Federal percentage of total costs (as stated
in the grant award agreement) to the total allowable incurred costs for the invoice(s) and
payment request submitted.
Section 5.1 Grant Payment Risk Level
Each sponsor will be assigned a grant payment risk level of nominal, moderate, or
elevated. A sponsor’s grant payment risk level pertains solely to their risk associated
with submitting grant payments and may differ than the risk level assigned to the
sponsor for other grant administration activities defined in the Airport Improvement
Program (AIP) Grant Oversight Risk Model Policy. Grant payment risk levels will be
determined based on the factors illustrated in Table 1. The RO/ADO must complete an
Airport Sponsor Risk Assessment (Appendix B) to document the assignment of a grant
payment risk level to each sponsor.
Table 1: Grant Payment Risk Levels
Grant Payment Risk-Level Risk Level Factors
Nominal Risk Sponsor Poses minimal risk of improper use of grant funds.
Moderate Risk Sponsor
1
Has a documented record of deviation from appropriate
grant payment processes and documentation; such as,
finding of lack of supporting documentation during payment
requests; repeated grant draw down irregularities; or Single
Audit findings requiring payments to the Federal
Government in excess of $100,000.
Elevated Risk Sponsor
Has a blatant or reckless violation of a grant agreement;
Finding of waste, fraud, or abuse; or a repeat of any of
the moderate risk factors.
1
All single grants over $20 million must be treated as a moderate risk regardless of the sponsors overall payment risk
level.
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Sponsor Financial Reporting Policy
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Section 5.2 Supporting Documentation
Supporting documentation must be uploaded electronically to all payment
requests in Delphi eInvoicing. The assigned grant payment risk level for each
sponsor will determine the supporting documentation that sponsors must provide
with each payment request. See Table 2 for the supporting documentation
requirements associated for each grant payment risk level. Supporting
documentation must be clearly labeled by sponsors to ensure it is identifiable
and searchable. States participating in the State Block Grant Program (SBGP)
must also meet the supporting documentation requirements in Table 2. All
payment requests from states participating in the SBGP must be based on billed
invoices and not requests from sub awardees. As a result, invoice summaries
down to the worksite level and billed invoice documentation must be provided as
required in Table 2.
In cases where sponsors submit a single payment request combining several
grants, required supporting documentation as outlined in Table 2 must still be
submitted by the sponsor. Sponsors must breakout supporting documentation
to clearly illustrate the grant that expenses are associated with in the payment
request. For example, an invoice summary document must be broken out and
attached for each grant that is associated with the payment request.
Table 2: Grant Payment Supporting Documentation Requirements
Documentation Requirements
Nominal
Risk
Sponsor
Moderate
Risk
Sponsor
Elevated
Risk
Sponsor
Invoice Summary: A summary document
generated by the sponsor that includes the
following information for each Pay
Application/Invoice: contractor name
2
, the date
of invoice, invoice number, billed amount,
breakout of AIP and Non-AIP participating costs,
invoice payment due date, worksite name, and a
short summary of services/material billed (See
Appendix C For Example).
X X X
Contractor Pay Request: Each Pay
Application/Invoice with Line Item Summary from
contractor (See Appendix D for Examples).
X X
2
The use of contractor here and throughout the document references not just construction contractors but also
vendors and any service providers that have billed sponsors for work under the payment request.
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Sponsor Financial Reporting Policy
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Documentation Requirements
Nominal
Risk
Sponsor
Moderate
Risk
Sponsor
Elevated
Risk
Sponsor
Sponsor Certification Letter & Other
Supporting Documentation: A letter from the
Airport Director/Grant Signer that certifies the
billed services meet contract pricing and bill
quantity requirements as well as all
documentation to support billing; such as, line
item details accompanying each pay request,
supplier invoices, inspector/observation reports
(sponsor or contractor prepared), all associated
sponsor/engineer analysis, and labor summary.
(See Attachment E for Examples).
X
Pursuant to 49 U.S.C. § 47107, it is the sponsor’s responsibility to maintain all original
source documentation that supports grant payments from the FAA to the sponsor and
payments made by the sponsor for the project. This includes all related documentation
for prime, as well as sub-contractor payments. These accounting records must be made
available upon request to the FAA, DOT’s Office of the Inspector General, Government
Accountability Office, independent auditors, and any other auditors acting on behalf of
those offices or the FAA, DOT, and Congress. In accordance with
2 CFR § 200 all documentation that supports grant payments must be retained for three
years after the grantee submits the final expenditure report.
Section 5.3 Matching/Cost-Sharing Requirements
When an award has specific cost-sharing (also known as matching) requirements as
outlined in 2 CFR § 200.306, such costs must:
• Be verifiable from the sponsor’s financial system of record;
• Be excluded as contributions for any other Federal award;
• Be necessary and reasonable for accomplishment of project or program
objectives;
• Be allowable under the Uniform Guidance and FAA policy, and included in the
approved budget; and
• Not be paid by the Federal government under another Federal award, except
where the Federal statute authorizing a program specifically provides that
Federal funds made available for such program can be applied to matching or
cost sharing requirements of other Federal program.
All conditions listed above apply to any third-party and/or volunteer services used to
meet the matching requirement. In addition, unrecovered indirect costs, including
indirect expenses on cost sharing or matching, may be included as part of cost sharing
only with the prior approval of the FAA.
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Sponsor Financial Reporting Policy
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Any payment request that includes a reimbursement amount that exceeds the allowable
Federal share may potentially be rejected, and the sponsor will be advised to resubmit
the payment request in an amount that equals the allowable Federal share.
In the event the required matching amount has not been satisfied, and/or the cumulative
Federal share has been exceeded, the sponsor will be required to reimburse the FAA in
the amount of the overpayment.
The sponsor may submit a credit memo in Delphi eInvoicing to offset the overpayment
against future expenditures if all of the following are present:
• The invoice is accurate and correct;
• The period of performance of the award has not expired;
• There are funds remaining on the purchase order; and
• Within 29 days from the day of the submitted credit memo, the sponsor will
submit subsequent reimbursement request(s) and the total must be $1.00 or
greater than the overpayment/credit memo amount.
After approval by the designated approving official, the credit memo will interface with
Delphi and automatically be put on hold. When a subsequent reimbursement request is
submitted, Enterprise Services Center (ESC) personnel will manually offset the two
amounts and pay out the difference.
If future Federal expenditures will be insufficient to offset the overpayment, the sponsor
will be required to refund the overpayment to the FAA with a check or direct deposit. If
the overpayment occurred or was uncovered at the end of the period of performance of
the award, the sponsor will be required to submit the refund with a check or direct
deposit only; the credit memo option is not available at the end of the period of
performance of the award.
Section 6: Review and Approval of Payment Requests
Section 6.1 Approval Process Overview
The Delphi eInvoicing system will automatically check the grant’s available balance in
Delphi to verify the availability of funds before a payment request may be successfully
submitted by a sponsor. Once a payment request is successfully submitted it will follow
the approval process assigned by the RO/ADO. There are two types of approval
processes in Delphi eInvoicing: “auto-approval” and “manual approval”.
Auto-Approval: This is an approval process whereby payment requests do not require
approval by the RO/ADO staff and are processed automatically for payment once
successfully submitted. However, all credit memo requests, refunds, and any payment
request that would bring the total drawdown request to more than 90 percent of the total
grant amount will be re-routed to a manual approval process requiring RO/ADO staff
approval (See Sections 6.9 and 7 for more information). Sponsors that are on an auto-
approval process are still required to submit supporting documentation as outlined in
Table 2 and all such documentation is subject to review and audit.
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Sponsor Financial Reporting Policy
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Manual Approval: This is an approval process whereby every payment request requires
the approval by RO/ADO staff before the payment request is processed for payment.
Section 6.2 Assignment of Approval Process
Payment approval processes in Delphi eInvoicing will be assigned on a sponsor level,
or in very limited cases, an individual grant level. The RO/ADO will assign each airport
sponsor an “auto-approval” or ”manual approval” process in Delphi eInvoicing based on
the sponsor’s grant payment risk level. Table 3: Sponsor Approval Process
Requirements specifies the approval process to assign for each grant payment risk
level. All nominal grant payment risk level sponsors must be assigned an “auto-
approval” review process. Terminal, environmental, land, planning, parking lots, or
multi-year projects may need more oversight but do not always necessarily require it. As
a result, only in cases were more oversight is deemed appropriate by the RO/ADO staff,
the RO/ADO is permitted to assign a manual approval process to these specific projects
under nominal sponsors. All other nominal sponsor grants for projects must be assigned
an auto-approval process. All moderate and elevated grant payment risk level sponsors
must be assigned a manual approval process in Delphi eInvoicing. Any sponsor that
has been granted a system waiver by the DOT must be assigned a manual approval
process regardless of their grant payment risk level.
Table 3: Sponsor Approval Process Assignment Requirements
Grant Payment Risk-Level Delphi eInvoicing Approval Process
3
Nominal
Auto-Approval – No RO/ADO approval required except for
payment requests within the final 10 percent of the grant
award amount.
At the discretion of the RO/ADO, specific grants to
nominal risk sponsors for terminal, environmental, land,
planning, parking lots, and multi-year projects may be
assigned a manual approval process. These projects
must still meet nominal risk sponsor documentation
requirements
Moderate
Manual Approval - Approval hierarchy must include at
least one level of RO/ADO approval.
All grants exceeding $20 million (excluding state block
grants) regardless of sponsor risk level must be assigned
a manual approval process
3
Sponsors that have been granted a system waiver from the U.S. DOT must be assigned a manual
approval process in Delphi eInvoicing regardless of their grant payment risk level.
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Grant Payment Risk-Level Delphi eInvoicing Approval Process
3
Elevated
Manual Approval – Approval hierarchy must include at
least two levels of RO/ADO approval of which one level
must be conducted by a RO/ADO manager.
Section 6.3 Approval Hierarchy
Approval hierarchies are created to assign approval processes for payment requests. It
is the responsibility of the RO/ADO manager to designate approvers for specific
sponsors and/or grants to a hierarchy, by which payment requests are routed to the
designated RO/ADO staff for electronic approval. When a new grant is issued, the
RO/ADO must assign a hierarchy for that grant. To establish or change a hierarchy, the
RO/ADO manager may submit the Hierarchy Assignment Form (Appendix F) to the help
desk. The form may also be submitted electronically at:
https://support-isupplier.esc.gov/hierarchy_forms.
To update, remove, or add FAA approvers to an existing approval hierarchy the
RO/ADO manager must complete the Approval Hierarchy Request Form (Appendix G)
and send it to the ESC Helpdesk to be processed in the system. This can be done at
any time. It is the responsibility of the RO/ADO manager to ensure approval hierarchies
in Delphi eInvoicing are current and accurate. In the limited circumstances where a new
approval hierarchy needs to be created the RO/ADO must complete the Approval
Hierarchy Request Form (Appendix G) and send it to the ESC Helpdesk to be
processed in the system. All new approval hierarchies must maintain the same naming
convention to be consistent with existing RO/ADO approval hierarchies. All approval
hierarchies must be labeled according to the following naming convention
“<AIP>-<RO>-<ADO>-<Approval Process Type>-<Number>.” For example, a manual
approval hierarchy in the Washington ADO would be labeled as
AIP-AEA-WAS-MANUAL-1 or an auto-approval hierarchy in the Central Region as
AIP-ACE-AUTO-1.
Section 6.4 Review of Payment Requests from Sponsors on Manual Approval
The RO/ADO staff will receive an email notification for all payment requests requiring
manual approval. The RO/ADO must review all payment requests electronically in
Delphi eInvoicing for those sponsors and/or grants assigned a manual approval
payment process. When reviewing the payment request the RO/ADO must ensure that
the following criteria are met before approving the payment request:
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• The cost is reasonable and allowable;
• All required supporting documentation has been attached to the payment
request;
• Work covered by the payment is already completed and in line with the project
schedule and/or scope of services; and
• Payment request is consistent with the most recent project progress and financial
performance reports provided by the sponsors.
A sponsor must only request payment in the amount of the Federal share of allowable
project costs that have been incurred by the Sponsor. These are costs that the sponsor
has been billed for and paid. However, there are times when advance payments may be
necessary. An advance payment is when a sponsor may request payment for services
billed but not yet paid by the sponsor. All advance payments must still provide
documentation showing that the payment is based upon the Federal share of invoices
and billing statements. Please see the most current version of FAA Order 5100.38
(Airport Improvement Program) for more details on advance payment policies.
Once payment requests are approved they will be electronically batched in Delphi and
sent to the U.S. Treasury for payment to the sponsor’s bank through electronic funds
transfer. Approved payment requests are electronically batched daily in Delphi and
sponsors should receive their payment within two business days of approval.
Section 6.5 Review of Payment Requests from Sponsors Issued a System Waiver
For those sponsors who have been granted a system waiver the process for reviewing
payment request will be different because the sponsor must initiate the payment request
from outside the system. All sponsors issued a system waiver will submit a hard copy of
the payment request to the RO/ADO outside the Delphi eInvoicing system. Once the
RO/ADO receives the hard copy payment request they must review it in accordance
with the criteria established in Section 6.4. If the payment request needs to be corrected
or cannot be approved following the review, the RO/ADO must contact the sponsor to
resubmit a new hard copy payment request with the corrections. Once approved the
RO/ADO must forward all payment request materials, including the supporting
documentation, to their designated FAA accounting technician to be processed
manually into Delphi Accounts Payable (A/P) module.
Section 6.6 Review of Payment Requests from Sponsors on Auto-Approval
There is no approval action necessary for payment requests submitted by sponsors
assigned an auto-approval process. However, the RO/ADO staff must still monitor
payments on a quarterly basis to ensure the required supporting documentation is
uploaded with each request and the drawdowns are consistent with sponsor project
progress and financial performance reporting. During this quarterly review the RO/ADOs
must select at least one grant per sponsor to review all payment requests submitted
during the quarter. The RO/ADOs must review payment requests for the following:
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• All required supporting documentation is uploaded with each payment requests;
• Each payment requested amount matches the supporting documentation;
• All work completed in the payment requests is consistent with the quarterly
construction progress reports submitted by the sponsor for the project; and
• There are no findings of any obvious unreasonable or unallowable costs.
RO/ADO staff must document this quarterly review by printing, reviewing, and initialing
each payment request. These documents should then be placed in the project file.
Section 6.7 Approval of Payment Requests
For sponsors on manual approval, the RO/ADO staff will automatically receive e-mail
notifications from Delphi eInvoicing when a payment request is submitted by a sponsor
and is awaiting action. RO/ADO staff must access Delphi eInvoicing and review
payment requests within 30 days of the payment request being made. Upon a
successful review, the RO/ADO must approve the payment requests in Delphi
eInvoicing. RO/ADO staff must not change the payment request amount or redistribute
the accounting line in which the payment amount draws from. All payments will be made
on a first-in-first-out accounting basis. Any changes to the accounting lines will be
performed by the designated FAA accounting technician. Once all the designated
approvers identified in the hierarchy workflow for the sponsor and/or grant have
approved the payment request it will be electronically batched in Delphi and sent to the
U.S. Treasury for payment. An email will also be sent to the sponsor informing them that
their request has been approved and is now pending payment.
For sponsors on auto-approval, no approval action is required and the payment will be
electronically batched in Delphi and sent to the U.S. Treasury for payment and sponsors
should receive their payment within two business days of approval.
Section 6.8 Rejection of Payment Requests
When the RO/ADO staff determines a requested payment amount is not reasonable,
allowable, or justified the entire payment request must be rejected in Delphi eInvoicing.
No partial payments will be allowed in Delphi eInvoicing. The RO/ADO staff rejecting the
payment must provide the reason the payment request was rejected and the corrective
action required in the comments field. All sponsors will be notified by Delphi eInvoicing
when their payment request is rejected. Once corrected, the sponsor must resubmit a
new payment request with the required supporting documentation again in Delphi
eInvoicing.
When sponsors submit a payment request or an invoice with less than one dollar
($1.00), FAA accounting will reject the invoice in Delphi eInvoicing. Due to system
limitations, Delphi only allows billing amount of one dollar ($1.00) or more. Sponsors will
be notified by the RO/ADO if a payment request is rejected. ECS accounting technician
will cancel the payment request and notify the RO/ADO for appropriate actions.
Except for final payments (Section 6.9), payment requests from sponsors on auto-
approval cannot be rejected in Delphi eInvoicing by the RO/ADO staff. If there are any
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errors in payment requests the sponsor must immediately contact their RO/ADO as well
as submit a credit memo, as outlined in Section 7, to correct the payment.
Section 6.9 Final Payment Request
As directed in 49 U.S.C. § 47111 Payments under project grant agreement, “Payments
totaling not more than 90 percent of United States Government’s share of the project’s
estimated allowable cost may be made before the project is completed if the sponsor
certifies to the Secretary that the total amount expended from the advance payments at
any time will not be more than the cost of the airport development work completed on
the project at that time.”
All payment requests within the final 10 percent of the Government’s share of grant
funds will require RO/ADO approval. For the purposes of complying with the 90 percent
statutory provision, a project FAA determines is “substantially complete”
4
can receive
payment within the last 10 percent of the grant agreement provided other parts of this
section are met.
The RO/ADO may authorize staff to approve payments beyond 90 percent of the total
grant amount in connection with specific projects that the FAA determines to be
substantially complete per the contract terms. This includes finding the work covered by
the payment is already completed and in line with the project schedule and/or scope of
service and may be used for its intended purpose; cost is reasonable and allowable;
and the request is consistent with the most recent project progress and financial
performance reports. The airport sponsor’s request must be grant specific and the
below conditions must be met for the specific project or projects within the grant
agreement that will be reimbursed by no more than 7.5 percent of the remaining 10
percent of grant funds. The RO/ADO must consider each grant on a case-by-case basis
before approving payments exceeding 90 percent of the grant award.
Conditions:
• the sponsor is in the “Nominal” risk category; and
• the project results in a complete, usable unit of work as defined in the grant
agreement.
It shall be the sponsor’s responsibility to submit all required documentation to the
RO/ADO, including the contract section, evidencing the sponsor has found the
project substantially complete per the contract requirements, for FAA’s
consideration in determining whether the project is substantially complete. The FAA
is the decision-maker in findings of substantial completeness for purposes of
approving payment under this policy.
The RO/ADO may not approve payment for the final 2.5 percent of the grant amount
4
Substantial completion is generally a defined term in a contract and is the stage of the project when
work is sufficiently complete in accordance with the contract documents so that the owner can occupy or
use the project for its intended purpose. The substantial completion date typically triggers retainage
release; the warranty period; determination of any actual or liquidated damages; the start of the statute of
limitations; and related actions.
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until all required closeout documentation (administrative, technical, and financial) is
received by the FAA.
Any grants on an auto-approval process will automatically be re-assigned a manual
approval process when the total drawdown amount reaches 90 percent of the grant
award amount to enable the required approval by RO/ADO staff for the remaining
10 percent of available grant funds.
If a grant amendment is initiated that would increase the award amount, the sponsor
may continue to request payment on those additional funds up until the total
drawdown amount equals the re-calculated 90 percent threshold. At that point,
grants will be automatically reassigned to a manual approval process.
The RO/ADO may exclude block grants to States participating in the State Block
Grant Program from the final 10 percent hold. In these cases, the State is not the
“sponsor” of a project and therefore the block grant is not subject to this provision.
In such cases the State may drawdown the full 100 percent of the grant award
amount prior to submitting financial closeout documentation. However, States are
required to follow the final 10 percent hold for all sub-award projects consistent
with the statute. Block grant states may also follow the criteria established for
payments within the final 10 percent of a sub-award project similar to the ADO
process outlined above.
Section 6.10 Holding Payment Requests
If a particular sponsor is determined to be in non-compliance with grant conditions
or is indebted to the U.S. Government the RO/ADO staff may put a hold on all
payment requests for a particular sponsor in Delphi eInvoicing by contacting their
FAA accounting technician to suspend the sponsor’s Delphi eInvoicing account. All
sponsors with a hold on payment requests will not be able to submit payment
requests in Delphi eInvoicing. The RO/ADO staff may not withhold payment for
approved incurred costs for more than 180 days unless the sponsor has failed to
comply with grant conditions, has been notified in writing by the Regional Airports
Division Manager, and has been given an opportunity for a hearing. RO/ADO staff
must contact the FAA Office of Airports Compliance, ACO-100, for specific
procedures and requirements before attempting to withhold payments for non-
compliance.
Sponsors are required to obtain and maintain a current active registration in SAM.gov
for the period of performance of the Federal award
5
. This requirement lasts until the
later of the submission of the final financial report or the sponsor’s receipt of the final
payment. Currently, SAM.gov utilizes Dun & Bradstreet’s Data Universal Numbering
System (DUNS®), a nine-digit number, as the unique identifier for applicants and
grantees receiving Federal financial assistance. In the near future, SAM.gov will
transition from DUNS® to a SAM-generated unique entity identifier (UEI). The UEI is
5
2 CFR §§ 25.110; 200(b); Appx. A, Sect. C.(1)
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a 12-character alpha-numeric value. Failure to maintain a current, active SAM.gov
registration—either DUNS® or a UEI—is grounds for holding payment requests.
6
The
Federal Government is currently working on this transition and more information will
be forthcoming.
Section 7: Improper Payments
An improper payment
7
is any payment that should not have been made or that was
made in an incorrect amount (including overpayments and underpayments) under
statutory, contractual, administrative, or other legally applicable requirements. This
also includes payment to an ineligible party, any payment for an ineligible good or
service, duplicate payment, payment for a good or service not received (except for
such payments where authorized by law), payment that does not account for credit
for applicable discounts, and any payment where insufficient or lack of documentation
prevents a reviewer from discerning whether a payment was proper. When an
improper payment results in a monetary loss to the Federal government the funds
must be recovered.
8
If a sponsor submits an improper payment in Delphi eInvoicing they must immediately
contact their RO/ADO. If the improper payment has not yet been approved the
RO/ADO must reject the payment request in Delphi eInvoicing.
Any improper payments that have already been processed and received by the
Sponsor require a credit memo (refund to the Federal government) be processed to
return the funds. The Sponsor will notify their RO/ADO that they are returning funds
for a specific grant. The RO/ADO will verify if the grant is open or closed.
Section 8: Award Funds Status at Closeout
Open Grants with Funds Remaining
If the grant is open and the Sponsor will be submitting a payment request in
Delphi eInvoicing, the following process must be applied:
•
Sponsors must contact their RO/ADO and submit a credit memo in Delphi
eInvoicing for the improper payment received, which may include overpayments,
or any payments received from the incorrect grant.
• Sponsors must not deduct the improper payment amount from the next payment
amount requested.
• Sponsors submitting a credit memo must upload in Delphi eInvoicing supporting
documentation, which includes an official letter from the sponsor’s authorized
representative who accepted the grant explaining the reason for the credit memo.
6
Sect. I. A. of Appx. A to 2 § CFR 25
7
2 CFR §§ 200.53 and 428; and PL 112-248.
8
2 CFR §§ 200.345, 410 and 411
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• All credit memo requests will require approval by the RO/ADO. Credit memo
requests will be automatically assigned a manual approval process in Delphi
eInvoicing regardless of the sponsor grant payment risk level.
• Approved credit memo requests will be held for 29 days in the system until a
subsequent payment request is made that will offset the returned amount.
• If after 29 days no subsequent payment has been made to offset the returned
amount, the credit memo will be removed from Delphi eInvoicing and sent to FAA
Accounts Receivable (A/R) for collections processing. A bill for collection is sent
by A/R to the sponsor.
• Sponsor will send the check to FAA Accounts Receivable referencing the
Purchase Order purchase order (PO) number to the following address:
DOT/Federal Aviation Administration
General Accounting
ESC/AMK 325
6500 S. MacArthur Blvd
Oklahoma City, OK 73169
Closed Grant or Open Grant with No Funds Remaining
When a grant is closed or is open but has no funding available and a credit memo
(refund) is necessary, the refund may be handled in one of two ways. The sponsor may
either issue a check or offset the Federal debt against a current award. Collecting a
refund via a check takes place. The following process must be applied outside the
Delphi eInvoicing system, and the process is as follows:
• Sponsor notifies the RO/ADO that they are returning funds for a specific grant.
• If appropriate Sponsor should submit supporting documentation for RO/ADO
review and approval. RO/ADO notifies their FAA accounting technician that the
funds will be returned to and provides the associated PO number to be reopened
in Delphi (if grant or PO is closed).
• RO/ADO instructs the Sponsor to send the check to FAA Accounts Receivable
(A/R) referencing the purchase order number and at the following address:
DOT/Federal Aviation Administration
General Accounting
ESC/AMK 325
6500 S. MacArthur Blvd
Oklahoma City, OK 73169
• Sponsor emails a copy of the refund check to the RO/ADO and FAA accounting
technician for reference.
• Once the returned funds have been received and processed by FAA A/R and
Accounts Payable (A/P), A/P will notify the RO/ADO to adjust the funds in the
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Office of Airports database system. The normal closeout process is followed at
this point.
If a grant is closed or is open but with no available funds, the sponsor may, with
approval of the FAA, offset the balance due to the FAA against incurred costs of a
current AIP award. The offset applies to a debt and not to the disallowed expenditures.
9
If the offset process is used to recover a refund due to the FAA, following are the steps
to complete the process:
• The FAA must establish the existence of a Federal debt in accordance with 2
CFR § 200.345. RO/ADO will submit a letter to the sponsor citing the amount of
debt; repayment terms; reference both the award and the debt that was
established under and the award to which the offset will apply.
•
RO/ADO will establish a special condition on both awards (i.e., award from which
the refund arose and award to which the offset will apply) to note the refund
amount, offset terms and other pertinent matters.
• Special conditions will be closed once the refund due has been satisfied.
Section 9: Financial Reporting
In accordance with 2 CFR § 200.327, sponsors are required to submit certain financial
reports to summarize grant expenditures and the status of project funds. These financial
reports must be collected outside of the Delphi eInvoicing system. Delphi eInvoicing is
limited to grant payments and does not currently provide the full capabilities to manage
financial reporting requirements. All sponsors must prepare and submit the following
financial reporting forms to the appropriate RO/ADO in accordance with the frequency
requirements specified below.
•
SF – 425, Federal Financial Report (Appendix H): This report, or approved
equivalent, must be submitted annually for each open grant, due 90 days after
the end of each Federal fiscal year, by sponsors to report outlays and program
income on a cash or accrual basis. In addition, this report must be submitted as a
final financial report during closeout in accordance with 2 CFR § 200.327 and 2
CFR § 200.343.
•
SF – 271, Outlay Report and Request for Reimbursement for Construction
Program (Appendix I): This report, or approved equivalent, is used for
construction projects only and must be submitted annually, due 90 days after the
end of each Federal fiscal year, by sponsors to report program funds expended
and Federal disbursements received. In addition, this report must be submitted
as a final financial report during closeout in accordance with 2 CFR § 200.343.
Please note that only those sponsors issued Delphi eInvoicing system waivers
are required to use this form with each payment request as well as annually.
9
Costs incurred under one award and applied or offset against a different award may result in ADA violations if the receiving
award was issued subsequent to the incurred costs.
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• SF-270, Request for Advance or Reimbursement (Appendix J): This report,
or approved equivalent, is used for non-construction projects only and must be
submitted annually, due 90 days after the end of each Federal fiscal year, by
sponsors to report program funds expended and Federal disbursements
received. In addition, this report must be submitted as a final financial report
during closeout in accordance with 2 CFR § 200.343. Please note that only those
sponsors issued Delphi eInvoicing system waivers are required to use this form
with each payment request as well as annually.
All valid obligations incurred under the Federal award must be liquidated within
90 days of the end of the period of performance, and a final financial report (and
all other required reports) must be submitted by the end of the liquidation period.
If the sponsor has unpaid obligations that can’t be settled within the 90-day
period, the sponsor may submit a liquidation extension request to the FAA
(usually in 30-day increments), based on the estimated amount of time needed to
satisfy the unpaid obligations. Once all obligations have been satisfied, the
sponsor must submit the final financial report for review and closeout of the
award.
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Appendix B. Oversight Area Risk Documentation Form
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Appendix C. Example of Invoice Summary
Summary of Sponsor Invoice # 15
Grant # 3-00-0000-001-2011
Contractor/Consultant
Name
Contractor
Invoice #
Invoice
Date
Due Date
Billed
Amount
AIP Costs
Non-AIP
Costs
Worksite Name
Short Summary of
Services/Materials
Billed
B & D Associates 7 3/30/2012 4/30/2012 $35,400.00 $31,860.00 $3,540.00
St. Augusta Regional
Airport
300 hours of project
assessment and
inspection
Point Industries 4 5/3/2012 6/3/2012 $325,312.00 $292,780.00 $32,532.00
St. Augusta Regional
Airport
Removal of 63 square
yards of pavement,
installed 3,837 tons of
crushed aggregate
base course and
installed 6,243 tons of
bituminous binder
course.
Total Requested
$324,640.00
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SAMPLE 1-INVOICE SUMMARY for DEVELOPMENT PROJECT (Cumulative)
GRANT RECEIPIENT INFORMATION PROJECT INFORMATION
Name: ABC Airport Authority
Airport: ABC Municipal Airport
Address: 2222 Airport Road
City/State: Airport City, USA
Grant Number: 3-XX-XXXX-XX
Description: Rehabilitate Taxiway
Reimbursement No.: 4
Federal Share %: 90%
(1a)
Vendor/Class/Description
(1b)
Contract
(1c)
Previously
Payments
X
(2)
Invoice
Number
(3)
Invoice
Date
(4)
Due Date
(5)
Invoice Amount
(6)
AIP Eligible Costs
(7)
Non-
Participating
Costs
(8)
AIP Share
Administrative
$ - $ - $ - $ -
Daily Dispatch - RFQ n/a
50.00
1 10/1/11 11/1/11 $ 50.00 $ 50.00 $ - $ 45
Daily Dispatch - IFB n/a
250.00
2 4/1/12 5/1/12 $ 250.00 $ 125.00 $ 125.00 $ 113
FedEx - Project Manual n/a
35.00
1 1/1/12 2/1/12 $ 35.00 $ 35.00 $ - $ 32
FedEx - Grant Agreement n/a
15.00
2 6/1/12 7/1/12 $ 15.00 $ 15.00 $ - $ 14
Engineering - Design Services
AIP Consultants, Inc.: (2012D127)
$60,000.00 $ 55,000.00
Design, Bid Services
2012D127-1 12/1/11 1/1/12 $ 15,000.00 $ 15,000.00 $ - $ 13,500
Design, Bid Services
2012D127-2 1/1/12 2/1/12 $ 25,000.00 $ 23,000.00 $ 2,000.00 $ 20,700
Design, Bid Services
2012D127-3 2/1/12 3/1/12 $ 15,000.00 $ 15,000.00 $ - $ 13,500
Design, Bid Services x 2012D127-4 4/1/12 5/1/12 $ 5,000.00 $ 5,000.00 $ - $ 4,500
Construction Phase Services - Observation and Testing
AIP Consultants, Inc.: (#2012C157)
$75,000.00
$0.00
Construction Services-March2012 x 2012C157-1 4/1/12 5/1/12 $ 2,500.00 $ 2,500.00 $ - $ 2,250
Construction Services-April 2012 x 2012C157-2 5/1/12 6/1/12 $ 10,257.00 $ 10,257.00 $ - $ 9,231
Construction
Airport Paving Inc. $800,000.00
$0.00
Construct Taxiway x 1 6/1/12 7/1/12 $ 50,000.00 $ 50,000.00 $ - $ 45,000
= Current Invoice Submittal
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x= Current Invoice Submittal TOTAL $108,884
Format Features
PREVIOUS REIMBURSEMENTS
- Allows tracking of all invoices submitted under the project to date.
- Groups invoices into appropriate cost classifications (e.g. Design)
- Identifies specific invoices addressed under current outlay
$ 47,903
$ 60,981
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Appendix D. Example of Contract Pay Request and Line Item Summary
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Appendix E. Example of Sponsor Certification Letter and Supporting
Documentation to Support Pay Requests for Elevated Sponsors
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Appendix F. Hierarchy Assignment Form
Hierarchy Assignment to Grant Purchase Orders
Hierarchy
Name
Grant
Number/
PO Number
PO Line
Num
PO Shipment
Num
PO Distribution
Num
Hierarchy
Name
Vendor
Name
Vendor Site
Code
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Appendix G. Approval Hierarchy Request Form
Approval Hierarchy Request Form
Section 1 Organization Information
What is the Operating Administration (OA) for this hierarchy?
Who is requesting this approval hierarchy change?
Request date?
Section 2 Basic Hierarchy Information
What is the unique name for this hierarchy?
What is the effective start date for this change? (optional)
What is the effective end date for this change, if any? (optional)
Hierarchy comments (optional)
Section 3 Auto-Approval Information (optional - only for auto-approved hierarchies)
Is this an auto-approval hierarchy (yes/no)?
If the answer to question 3.1 is YES, what is the payment request amount, as a percentage of
the total grant amount that will trigger an FYI notification?
Provide the email addresses, one per cell, for the users who should receive an FYI notification
when the threshold defined in 3.2 is reached.
If the answer to question 3.1 is YES, what is the expended balance threshold, as a percentage
of the total grant amount that will cause a payment request to require manual approval?
Section 4 Manual Approval Hierarchy Details (required for all hierarchies)
4.1 The number of days a payment request will wait for action to be taken before an escalation
notification is sent.
Tier 1 (required)
Provide the email addresses, one per cell, for the users in Tier 1 of the manual approval
hierarchy.
4.3
Provide the email addresses, one per cell, for the users who should receive escalation
notifications when the threshold in 4.1 is reached.
Tier 2 (optional)
Provide the email addresses, one per cell, for the users in Tier 2 of the manual approval
hierarchy.
4.5 Provide the email addresses, one per cell, for the users who should receive escalation
notifications when the threshold in 4.1 is reached.
Tier 3 (optional)
Provide the email addresses, one per cell, for the users in Tier 3 of the manual approval hierarchy.
4.7 Provide the email addresses, one per cell, for the users who should receive escalation
notifications when the threshold in 4.1 is reached.
Tier 4 (optional)
Provide the email addresses, one per cell, for the users in Tier 4 of the manual approval hierarchy.
4.9 Provide the email addresses, one per cell, for the users who should receive escalation
notifications when the threshold in 4.1 is reached.
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