Skip to content U.S. Department of Transportation/Federal Highway AdministrationU.S. Department of Transportation/Federal Highway Administration

Office of Planning, Environment, & Realty (HEP)
Planning · Environment · Real Estate

HEP Events Guidance Publications Glossary Awards Contacts

Prior Approvals for Non-Construction Grants & Cooperative Agreements to State & Local Governments

07/25/2006 01:57:41 PM
Kenneth N Petty
HQs Planning Memos and Guidance, Federal Highway Administration,

Budgetary Changes

  1. Additional funds. Increase in federal funds in grant. [49CFR18.30(c)(1)(i)]
  2. Rebudgeting. Cumulative transfers over 10% of the total budget among direct cost categories or among programs, functions or activities if budgeted separately, when the federal share exceeds $100,000. [49CFR18.30(c)(1)(ii)] (No requirement for prior approval for budget revisions in grants less than $100,000.)
  3. Trainee costs. Transfer of funds allotted for training allowances (i.e., from direct payments to trainees to other expense categories). [49CFR18.30(c)(1)(iii)]
  4. Carryover. Charging costs incurred in a subsequent funding period to unexpended funds from a previous period. [49CFR18.23(a)]
  5. Liquidation of obligations. Liquidation of obligations more than 90 days after the end of the funding period. [49CFR18.23(b)]

Programmatic Changes

  1. Change in scope. Change in scope or objectives of grant supported activities. [49CFR18.30(d)(1)]
  2. No-cost extension. The need to extend the period of availability of funds. [49CFR18.30(d)(2)]
  3. Change in key person. If the grant award specifies prior approval for the replacement, absence or significant change in responsibilities of an expressly identified key person or for the principal investigator in research. [49CFR18.30(d)(3)]
  4. Transferring substantive programmatic work. Subgranting, contracting or otherwise transferring substantive project activities to a third party. [49CFR18.30(d)(4)]


  1. Certain in-kind match. In-kind match at fair market rental rate for donated land or at full market value for donated equipment or buildings. [49CFR18.24(e)(2)(i)]

Real Property

  1. Transfer of title. Transfer to a third party of title to real property acquired under a grant. [49CFR18.30(d)(3)]

Procurement – Only applies to local and Indian tribal governments who are direct grantees. Does not apply to States, which are to use their own procurement procedures [49CFR18.36(a) or to subgrants by a State to local or Indian tribal governments who are to use procedures specified by the State [49CFR18.37(a)]. The simplified acquisition threshold is currently $100,000.

  1. Non-competitive contracts. Procurements expected to exceed the simplified acquisition threshold which are sole source or without competition, and modifications or change orders, unless price reasonableness can be determined on the basis of catalog or market price or prices set by law or regulation. [49CFR18.36(g)(2)(ii)]
  2. "Brand-name" contracts. Procurements over the simplified acquisition threshold which specify a "brand-name" product. [49CFR18.36(g)(2)(iii)]
  3. Awards to other than the low bidder. Proposed awards over the simplified acquisition threshold to other than the apparent low bidder under a sealed bid procurement [49CFR18.36(g)(2)(iv)]
  4. Contract modifications. A proposed contract modification changing the scope of a contract or increasing the contract amount by more than the simplified acquisition threshold. [49CFR18.36(g)(2)(v)]

Program Income

  1. Addition or matching use of income. Use of program income to meet cost sharing or matching requirements or to add to the funds already committed to the grant. [49CFR18.25(g)]

Other Actions

  1. Information collection. Collection of information from others if they are told that the information is being collected for or on behalf of the Federal grantor agency. [5CFR Part 1350, Controlling the Paperwork Burden on the Public]
  2. Reporting. Any change in the prescribed frequency or due date of reports. [49CFR18.41(a)(6)]
  3. Restrictions in the grant award. Using funds for any purpose or type of cost that was expressly disapproved as a condition of the grant. [implicit in all grants]

Allowable Costs [References are paragraphs in OMB Circular A-87, Attachment B]

  1. Advisory council (or committee) costs as a direct cost. [B.2]
  2. Compensation for personal services: Abnormal or mass severance pay. [B.8.g.(3)] Substitute system of supporting documentation for salaries and wages of employees who work on multiple activiteis or cost objectives. [B.8.h.(4)] Substitue system for allocating salaries and wages. [B.8.h.(6)]
  3. Equipment and other capital expenditures. [B.15.b.(1) and (2)]
  4. Insurance on property owned by the federal government. [B.22.b.(2)]
  5. Uninsured losses (including property losses and liabilities to third parties) which could have been covered by permissible insurance (except nominal deductible amounts or other minor uninsured losses such as ordinary spoilage, breakage, etc.). [B.22.c.]
  6. Membership in civic and community, social organizations as a direct cost. [B.28.c.]
  7. Preaward costs. [B.31.]
  8. Proposals costs as a direct cost. [B.33.]
  9. Rearrangements and alterations of facilities. [B.35.]
  10. Travel costs of general government officials (see B.19.). [B.43.a.]
  11. Foreign travel. [B.43.e.]
Updated: 12/03/2012
HEP Home Planning Environment Real Estate
Federal Highway Administration | 1200 New Jersey Avenue, SE | Washington, DC 20590 | 202-366-4000