DOT 4600.17A

1. PURPOSE. This Appendix provides departmental guidance for implementing OMB Circular A-102, Grants and Cooperative Agreements with State and Local Governments, 49 CFR part 18, Uniform Administrative Requirements for Grants and Cooperative Agreements with State and Local Governments, OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, and 49 CFR part 19 (same title).

2. BACKGROUND. On March 12, 1987, the President directed all affected agencies to issue a common grants management rule to adopt Governmentwide terms and conditions for financial assistance to State and local governments. OMB Circular A-102 was revised in 1988 to provide additional guidance to Federal agencies. DOT issued its common rule on March 11, 1988, as 49 CFR part 18.  The common grants management rule allows States to use their own procedures to manage their financial management, equipment, and procurement systems. OMB Circular A-102 was revised on October 14, 1994, to include updated direction on:(1)implementation of the metric system; (2) review of infrastructure investment; (3) implementation of the Resource Conservation and Recovery Act; and (4) public announcement of the amount of Federal funds used in certain contract awards.
   Administrative requirements for management of grants to nonprofit organization programs are contained in 49 CFR part 19, originally published as an interim final rule on April 4, 1994. The rule incorporates and reflects the provisions of OMB Circular A-110. The revised Circular was developed by an interagency task force for governmentwide use in a common rule format to facilitate regulatory adoption by executive departments and agencies.
   Part of these efforts included DOT obtaining required paperwork clearance for all standard forms and reporting requirements in 49 CFR parts 18 and 19. However, OMB approval must be obtained for any additional reporting requirements.  Both rules permit deviations, but they must be based on statute or approved by either OMB (for class deviations) or the Office of the Secretary (for individual cases).

3. REQUIRED ACTIONS.
   • The Assistant Secretary for Administration shall issue additional specific instructions for implementing OMB Circulars A-102 and A-110, and 49 CFR parts 18 and 19 only in those instances where the prescribed requirements need further clarification and/or implementation.

   • The operating administrations and secretarial offices shall:
     1. Establish additional instructions, if required, for implementing the above directives.

     2. If imposing additional requirements on "high risk" grantees, as authorized by 49 CFR 18.12, or 49 CFR 19.14, forward copies of such notifications to the Assistant Secretary for Administration and the Assistant Inspector General for Auditing.

     3. In addition to guidance provided in Section 2.(h) of OMB Circular A-102, and Section 16 of OMB Circular A-110, regarding resource conservation and recycling programs, implement the provisions of Executive Order 13101, Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition.