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211 Project Reporting and Closeout Agencies and sponsors implementing an SIP are sometimes not fully aware of project report- ing and closeout requirements and consequently need to generate reports and records at closeout that could have been created and updated during project activities. Failure to maintain accurate records for programs funded by the AIP can have negative results. Some airports have had funds withheld until sponsors provide appropriate documentation to comply with federal assurances. It is advisable that a reporting and closeout plan be given a high priority when establishing a program work plan, whether sponsors intend to handle administrative tasks in house or use consultants for program management activities. SIPs and their associated reporting and closeout activities gener- ate a tremendous volume of files and documentation. All of these items must be available for audit. This section of the guidelines outlines reporting and closeout requirements; however, manag- ing a successful SIP requires agencies and sponsors to review, in detail, the reporting require- ments and closeout procedures outlined in AIP Handbook, FAA Order 5100.38C and 49 CFR 18.40.1 It is advisable that sponsors or grant administrators consult with their regional FAA ADO to verify what submittals they require since the FAA ADO may have its own requirements for reporting and closeout activities. 12.1 Regulatory Agencies SIPs are large, complex projects that require the assistance of multiple agencies and the careful coordination of internal program staff. It is sometimes the case that an SIP is the largest single project receiving funding in an airportâs ACIP. Because of the amount of funding required for these types of projects, it is likely that an audit will take place at some point during the project. Understanding regulatory agencies and the role they serve is crucial to successfully preparing for the possibility of an audit. The following agencies regulate and provide guidance on reporting and closeout procedures. An SIPâs guidelines should incorporate the reporting and closeout regulations disseminated by these agencies. 12.1.1 U.S. Department of Transportation The U.S. DOT is a federal department administered by the United States Secretary of Trans- portation. The mission of the U.S. DOT is to âserve the United States by ensuring a fast, safe, efficient, accessible, and convenient transportation system that meets our vital national interests C H A P T E R 1 2 1 U.S. DOT, FAA, FAA Order 5100.38C, Airport Improvement Program Handbook, June 28, 2005.
212 Guidelines for Airport Sound Insulation Programs and enhances the quality of life of the American people, today and into the future.â2 The FAA is an agency within the U.S. DOT. Open and consistent communication with the FAA ADO is encouraged throughout each step in an SIP, especially during project reporting and closeout. While Sections 12.2 and 12.4 outline reporting and closeout requirements, the ADO may have its own requirements and should be consulted. If there is any doubt regarding what is required when reviewing the published regulations outlined in Section 12.2, contact the local ADO. FAA representatives are well versed in the requirements and can provide guidance. 12.1.2 Office of Management and Budget3 The OMBâs predominant mission is to assist the president in overseeing the preparation of the federal budget and to supervise its administration in executive branch agencies. In help- ing to formulate the presidentâs spending plans, the OMB evaluates the effectiveness of agency programs, policies, and procedures; assesses competing funding demands among agencies; and sets funding priorities. The OMB ensures that agenciesâ reports, rules, testimony, and proposed legislation are consistent with the presidentâs budget and administration policies. In addition, the OMB oversees and coordinates the administrationâs procurement, financial management, information, and regulatory policies. In each of these areas, the OMBâs role is to help improve administrative management, develop better performance measures and coordinating mecha- nisms, and reduce any unnecessary burdens on the public. Audits may be required for SIPs and must be conducted per the OMBâs standards and regula- tions. Section 12.5 provides more information on audits of SIPs. 12.1.3 Office of Inspector General (OIG)4 The Office of Inspector General conducts independent audits, inspections, and investigations that advance the missions of the Department of State and the Broadcasting Board of Governors. The OIG (among other things) provides leadership to promote integrity, efficiency, effective- ness, and economy, while preventing and detecting waste, fraud, abuse, and mismanagement of government funds. If an SIP is audited, the OIG actively participates in the audit process. Section 12.5 provides more information about the audit process. 12.2 Reporting and Closeout Guidelines In the following are the FAA requirements and specific regulations that deal with project reporting. Always consult with the regional ADO regarding any questions on the reporting requirements. Use the FAA as a source of information and direction. 12.2.1 AIP Handbook, FAA Order 5100.38C The AIP Handbook, FAA Order 5100.38C, Chapter 12, Section 2, Paragraph 12215 requires that a project sponsor ensure that project work is carried out in accordance with plans and specifications, that time schedules are observed, that federal labor and civil rights provisions are followed, and that all other terms and conditions in the contract documents and grant agreement are implemented. 2 What We Do, United States Department of Transportation, updated Dec. 19, 2011, http://www.dot.gov/about.html#whatwedo. 3 See the website of the Office of Management and Budget, www.whitehouse.gov/omb. 4 See the website of the Office of Inspector General, http://oig.hhs.gov/. 5 See note 1, Chapter 12, Section 2, Paragraph 1221, Sponsorâs Responsibilities.
Project Reporting and Closeout 213 12.2.2 49 CFR 18.40 Monitoring and reporting requirements for grantees are addressed in 49 CFR 18.40. Grant recipients are responsible for managing the day-to-day operations of grant activities to ensure compliance with applicable federal requirements. They must also submit a performance report for each fiscal quarter that, at a minimum, includes the following items: 1. A comparison of proposed objectives to actual accomplishments for the reporting period. (Outline the baseline schedule, revised schedule, and actual completion date.) 2. Reasons for any slippage or lack of accomplishment in a given area. 3. Impacts on other AIP-funded projects. 4. Impacts to PFC,6 facilities and equipment, or owner-funded projects. 5. Identification and explanation of any anticipated cost overruns. (Provide a summary of addi- tional costs, change orders, and so forth.) When grants have been awarded for SIP projects with multiple phases that are covered under a single grant, grant recipients should submit performance reports for each project. The tracked accomplishments will vary according to the type of project. Following are recommended task items for two types of projects: design only and construction/equipment. A. Design-Only Project Task Items â¢ Completed grant agreement. â¢ Notice to proceed to architectural or engineering firm. â¢ Submittal of final plans and specifications. â¢ Submittal of design grant closeout (SF-271, invoices). B. Construction/Equipment Project Task Items â¢ Completed grant agreement. â¢ Notice to proceed to contractor. â¢ Substantial completion. â¢ Final acceptance. â¢ Submittal of grant closeout documentation. 12.3 Documentation Organization It is imperative that airport sponsors or grant administrators implement a project reporting and closeout plan for all SIP-grantâfunded projects. If the airport sponsor or grant adminis- trator assists with program management activities, the sponsor or grant administrator should include specific tasks in the scope of work to clearly identify FAA reporting timelines and required reports. It is not uncommon for a sponsor to delegate the responsibility of tracking eligible grant expenses to its finance department. 12.3.1 Flow Chart Airport sponsors and grant administrators need to invest the time to map out the entire reporting process. A step-by-step diagram and reporting structure take the guesswork out of the decision-making process. It is recommended that sponsors and grant administrators consider using a certified workflow process consultant to assist with developing these processes. Key spon- sor decision makers and consultant staff should also participate in the processâan essential 6 U.S. DOT, FAA, AC 150/5000-12, Announcement of Availability â Passenger Facility Charge (PFC) Application (FAA Form 5500-1), July 15, 1994.
214 Guidelines for Airport Sound Insulation Programs step that allows decision makers the opportunity to provide input and see what is required to successfully manage an SIP. A reporting and closeout workflow also helps to strengthen relationships between the com- munity and the airport. When key decision makers are involved in the setup, they are able to see how the SIP touches more than just noise-affected property owners. See Appendix E, Exhibit 1 for a sample administrative workflow diagram. 12.3.2 Consultant Agreements It is strongly encouraged that sponsors and grant administrators create a separate task item within their consultant agreement that specifically addresses the scope of work for the prepa- ration and submittal of closeout documentation. The sponsor or grant administrator should establish that the time of performance for this deliverable is 90 days from project acceptance. To facilitate tracking the status of this deliverable, it is recommended that a specific payment provision based on a reasonable lump sum is stipulated as opposed to including this work as part of a cost-plus fixed fee of the construction observation services. Consultant agreements that combine construction observation services and project closeout services create a situation where the project closeout task may be forgotten or overlooked. This situation can result in delays to the closeout of the project grant. Make sure that all closeout procedures are included. When a consultant is hired to assist with any of the program management activities, the spon- sor or grant administrator is required to comply with the requirements listed on the Selection of Consultants assurance form. See Appendix E, Exhibit 2, Selection of Consultants, for further information. 12.3.3 Reporting Schedule Establishing a reporting schedule is a key component of the reporting and closeout plan. Work- ing with the regional ADO and designated representative to discuss reporting timelines is critical to maintaining open lines of communication and identifying in advance any potential issues that may arise. Under 49 CFR 18.40, a grantee is required to submit a performance report for each fiscal quarter. This report must be submitted within 30 days of the end of the reporting period. 12.3.4 Reporting Tools SIPs and their associated reporting and closeout activities generate a tremendous volume of hard copy files. It is not unusual for a single construction contract consisting of 25 to 30 homes to generate paper files that are an estimated 7-ft to 10-ft tall. Program tracking systems, such as case management systems (CMS) and document management systems (DMS), have become an integral part of SIPs (see Figure 12.1). It is necessary to identify and attempt to contact all property owners eligible for participation in an SIP; the CMS/DMS is instrumental in ensuring that all contact attempts can be documented. In some states, tracking and documentation of good-faith efforts to contact eligible property owners is required. Airports that have established or are considering establishing an SIP must also have an NCP in place as an element of their Part 150 study. The NCP identifies an estimated number of noise-affected parcels and population density. The Part 150 study consultant team generally uses county assessorâs information to calculate these estimates. However, it is not sufficient for SIPs to rely on county assessorâs information; an existing land use survey should be conducted
Project Reporting and Closeout 215 Figure 12.1. Screenshots of case management and document management systems. Images Courtesy of Psomas.
216 Guidelines for Airport Sound Insulation Programs to identify the number of noise-affected parcels. Using the mapping and data collection features of the CMS can assist in identifying all eligible properties. The existing land use survey can be conducted without the use of a CMS, but it is very labor intensive and subject to error and addi- tional scrutiny. To maximize the benefits of a CMS, be sure to provide adequate training for all users of the program. The basic requirements and features of a program tracking system are that the system: â¢ Must track program costs, â¢ Must track eligible FAA reimbursable expenses, â¢ Must identify eligible and non-eligible parcels, â¢ Must identify all participating and non-participating property owners, â¢ Should ideally be web-based, â¢ Must be inclusive of program database, â¢ Must provide parcel mapping, â¢ Must archive all program files in searchable format, â¢ Must have the ability to track users and user rights, and â¢ Must be hosted in a secure environment. 12.4 Grant Closeout The closeout of a grant is the process by which the regional ADO and the project sponsor or grant administrator perform the necessary final administrative and financial actions to com- plete all requirements set forth in the grant agreement. For SIPs, the closeout process addresses three areas: project work completion, administrative requirements, and financial requirements. The grant closeout documents and reports that may be required for each area are: Project Work Completion â¢ As-built plans. â¢ Updated property map. â¢ Final construction project closeout report. Administrative Requirements â¢ Final outlay report (SF-271). â¢ Summary of DBE use. â¢ Property accountability. â¢ Submittal of federal assurances. Financial Requirements â¢ Final project cost summary. â¢ Block grants. â¢ Excess payments. â¢ Fiscal adjustments. Section 12.4.2 discusses these documents and reports. The goal of the FAA is to close out active grants as quickly as possible or within the allowable grant period of use (typically 3 years from acceptance). It is important that all parties involved fulfill these requirements promptly so that unnecessary delays in closing a grant can be avoided. Once all work is complete per the approved plans and specifications and the final inspection results in a recommendation of project acceptance, the sponsor or grant administrator must proceed with finalizing all project costs and assembling the required closeout documentation in a timely manner.
Project Reporting and Closeout 217 12.4.1 Timely Submittal of Closeout Documentation By entering into a grant agreement, a sponsor or grant administrator agrees to a grant condi- tion that requires it to carry out and complete the project without undue delay. Completion of the project does not end with the physical completion of the work; project completion includes satisfying the requirements for administrative and financial closeout of the grant. Sound insulation is a program containing multiple projects. Therefore, a single grant may be used to fund multiple construction contracts. If the grant application is for more than one project, use the end date of the project with the longest construction period to determine the deadline to collect the required submittals to finalize the grant closeout. All projects listed under this grant must have completed all the general closeout requirements in order to submit a sum- marized report. The sponsor should strive to submit all final closeout documentation to the regional ADO within 90 days of the final acceptance from the contractor. The regional ADO will consider extensions to this time limit if unique circumstances prevent reasonable determina- tion of the final project costs. These circumstances can include mitigating contractual issues or resolving disputes regarding the final construction pay estimate. If for some reason there is a delay in closing an active grant beyond the required time period, consult with the regional ADO as soon as possible. If the project is being managed by a staff scheduler, it is important to keep the staff scheduler informed if there are significant issues that will affect the schedule in order to allow adequate time to advise the regional ADO of a potential delay. Program sponsors should notify the regional ADO of any potential delays that may hinder a project from hitting the target closeout date. 12.4.2 Final Project Closeout Report The necessary closeout documentation can vary depending on the type and size of the project. Typically, a sponsor or grant administrator must submit the items listed in the following to for- mally close out an AIP grant project. Sponsors or grant administrators may omit some items if they are not relevant to the specific project. It should be noted that the sponsor may be required to submit some documentation (e.g., commissioning data) before finalizing closeout of the project. A project sponsor or grant administrator should consult with the ADO to determine what closeout items are necessary based on the type and size of the project and when each submittal is required. It should be noted that the regional ADO reserves the right to request additional information consistent with the approved collection of information for the AIP grant. A. As-Built Plans As part of closeout, as-built plans for airport projects involving construction must be submit- ted. For SIPs, the as-built plans are plans showing the retrofit treatments specified for each home, church, or school that is noise insulated. At the ADOâs discretion, certification from the sponsor or grant administrator that as-built plans have been received and will be retained for future use may be accepted. Another option, at the discretion of the ADO, is to accept an electronic version of the as-built plans. The sponsor or grant administratorâs project manager must request and retain a set of as-built project drawings for future reference; however, the actual submittal of the record drawings to the regional ADO is not necessary unless specifically requested by the FAA project manager. Projects that include work on FAA facilities may require submittal of record drawings to the regional ADO at the conclusion of the project. The FAA project manager should be consulted to determine whether record drawings should be sent to the regional ADO. B. Updated Property Map As part of the adopted Part 150 study, a property map is included. The map shows the noise- affected areas and proposed boundaries for sound insulation. Updating the airport land use plan, if
218 Guidelines for Airport Sound Insulation Programs any changes are made, is needed to illustrate project accomplishments. An FAA Exhibit A property map (FAA Order 5190.6B, FAA Airport Compliance Manual) records all interests in land main- tained by the airport. Interests in land will include avigation easements secured as part of SIPs. See Appendix E, Exhibit 3 for a sample property map. C. Final Construction Project Closeout Report The sponsor or grant administrator must prepare and submit a final construction report that provides an appropriate and accurate record of the project. The format and extent of this report will vary depending on the type and size of the project. The FAA project manager should be consulted with questions regarding what items need to be addressed in the final report. See Appendix E, Exhibit 4, Project Closeout Report for further information. At a minimum, unless otherwise approved by the FAA project manager, the report must address or contain the following items: Project Summary â¢ Include in the summary the location of the airport, grant agreement date, and amount of any grant amendments that may have been granted. â¢ Brief narrative of work accomplished. Include explanation for any deleted work item and description of non-participating work item. â¢ Summary of key milestone dates for receipt of bids, notices to proceed, substantial comple- tion, contract date, final inspection, and final acceptance. â¢ Final acoustical engineerâs report. â¢ Contract time, including an explanation of liquidated damages (if required) and justification for weather delays (calendar contracts require submittal of National Weather Service data to justify weather events in excess of the normal monthly events). Executive Summary â¢ Include a brief summary of activities and compliance with federal assurances. â¢ Program budget, describing program budget and expenses. â¢ Historic properties, describing any Section 106 activities and related construction to historic properties. â¢ Land use compatibility â a list of statistics that summarize sound mitigation efforts and com- patible land uses. â¢ Labor provisions â a statement of compliance with contract labor provisions (payroll reviews, complaints, and so forth). Reference AC 150/5100-6 for more information. Also include a summary of any complaints/findings and how they were resolved. â¢ Administrative costs, briefly explaining claimed costs. Refer to Section 310.c of FAA Order 5100.38C for eligibility provisions. â¢ Engineering costs, briefly explaining claimed costs and delineating eligible and ineligible costs. â¢ Force account. Identify the FAA approval date, provide a listing of claimed costs, provide sup- porting documentation if not already submitted with drawdown documentation, and include claims for wages and salaries (which must comply with OMB A-87 requirements and may not be arbitrary or prorated). Sponsors and grant administrators may not claim indirect costs unless they have a prior-approved cost allocation plan. â¢ Construction costs. Summarize final contract quantities, delineate eligible and ineligible costs, identify added or deleted work items, and explain/justify underruns and overruns. Include a summary of change order and supplemental agreements. â¢ Buy American provisions. Provide the sponsorâs or grant administratorâs statement addressing whether the contractor complied with Buy American provisions and how the sponsor or grant administrator verified compliance. The sponsor or grant administrator must maintain documen- tation that supports contractor compliance with Buy American provisions. Upon request of the
Project Reporting and Closeout 219 FAA project manager, the sponsor or grant administrator must provide this documentation to the FAA as part of the closeout documentation. At a minimum, the sponsor or grant administrator must maintain product information sheets and a shop drawing submittal log or summary table. Project Cost Summary â¢ List all costs as described and a brief explanation. Partial Payment History Summary â¢ Provide an explanation and financial backup for all payments requested for grant reimburse- ment leading to final payment. Change Order Summary â¢ Provide as part of the financial summary any changes to the budget that were affected by consultant contract amendments. â¢ All construction change orders should be noted on the project cost summary. Final Inspection and Punch List Item Clearance â¢ Provide all inspection and punch list items and reports identified during interim and final inspections. Mandatory Project Review Comments and Certification Summary â¢ Completion of checklist is required, as noted on project closeout report (see Appendix E, Exhibit 4). Disadvantaged Business Enterprise Program Participation Summary â¢ All sponsors or grant administrators are required, as a condition of project approval, to assume certain DBE obligations as set forth in 49 CFR Parts 23 and 26. Complaints alleging discrimi- nation under the DBE program should be referred to the regional civil rights offices. See AIP Handbook, FAA Order 5100.38C, Chapter 14, Section 2 for further information. â¢ Typically, sound insulation program DBE requirements are part of the overall governing body goal established by the Equal Employment Opportunity (EEO) office. The EEO office will usually fill in the required DBE use forms. In most cases, the SIP manager needs to provide basic information (as illustrated in Appendix E, Exhibit 4, Project Closeout Report). Final Payment Recommendation and Project Amendment Requirement â¢ Excess payments. If the final financial report indicates that payments have been made that exceed the federal share of the estimated allowable costs or that the sponsor or grant adminis- trator has received interest on federal funds to which it is not entitled, this amount constitutes a debt to the federal government. The accounting office should be informed of the amount and asked to send a notice to the sponsor or grant administrator that the debt should be paid within 30 days or a charge for interest and penalties in accordance with the Federal Claims Collection Standards will be assessed. [See AIP Handbook, FAA Order 5100.38C, Paragraph 1304(b) for guidance regarding offset against another grant.] â¢ Fiscal adjustments. It may be necessary to make upward or downward adjustments as a result of an audit, grant amendments, or resolution of disputed costs. D. Final Outlay Report Standard Form SF-271 Per 49 CFR 18.41, grantees must submit a final outlay report indicating all claimed costs under the subject grant. The sponsorâs or grant administratorâs authorized official must sign this report. The FAA will reject unsigned outlay reports. See Appendix E, Exhibit 5, Final Outlay Report Form 271 for further information.
220 Guidelines for Airport Sound Insulation Programs E. Property Accountability A sponsor or grant administrator rarely acquires equipment expressly to carry out a grant for SIPs. However, if a sponsor or grant administrator uses federal funds to acquire equipment to carry out the grant, an inventory of all equipment with a current, per-unit fair market value in excess of $5,000 must be submitted as part of the closeout package. Equipment no longer needed for airport purposes may be sold or retained by the sponsor or grant administrator. The federal share of the current fair market value must be deducted from the grant amount or reimbursed to the FAA. F. Submittal of Federal Assurances Submit the Construction Project Final Acceptance (Appendix E, Exhibit 6), Project Plans and Specifications (Exhibit 7), Equipment Construction Contracts (Exhibit 8), and Real Property Acquisition (Exhibit 9) forms, if applicable. The sponsor or grant administrator must complete the Construction Project Final Acceptance form and submit to the FAA standard certification attesting to the satisfactory completion of the work in conformance with the approved plans and specifications. Regarding this certification: â¢ Each certification statement requires the sponsor or grant administrator to indicate a response. â¢ Negative replies to questions on the certification require an explanation. â¢ The certification must be signed and dated by an authorized person. G. Final Project Cost Summary The sponsor or grant administrator is required to submit a final financial report to the FAA in accordance with 49 CFR 18.41 and 18.50. This report is required even if the sponsor or grant administrator has already received payments equal to the maximum obligation of the United States stated in the grant agreement. For construction and non-construction projects, the final report must be made on the form the sponsor normally uses to request payment (i.e., SF-270 or SF-271 in cases of reimbursement by Treasury check or SF-272 if a letter of credit has been used). The final financial report may also serve as the request for final payment when 100% progress payment has not been made or when an adjustment to the 100% progress payment is required. See Appendix E, Exhibit 10, Financial Spreadsheet. H. Block Grants If the sponsor or grant administrator has used block grant funding to support its SIP, there are additional requirements to be coordinated and complied with the FAA. 12.5 OMB 133 Audit Since most sponsors receive grants from more than one federal agency, cognizant agencies are assigned based on the federal agency that provides the predominate amount of direct fund- ing in accordance with OMB Circular A-133, Audits of States, Local Governments, and Non- profit Organizations. Grant Assurance #13 (Grant Assurances, Airport Sponsors, Section C, #13 â Accounting System, Audit, and Record Keeping Requirements) and 49 CFR Part 18 require sponsors or grant administrators that expend $500,000 or more a year in federal funds to conduct a single or program-specific audit for that year in accordance with the Single Audit Act of 1984 (as amended) and OMB Circular A-133. The Single Audit Act of 1984 establishes the procedures to ensure uniformity in the process of conducting audits. This audit is typically not conducted at the same time as the grant closeout.
Project Reporting and Closeout 221 There are four parties involved with the OMB Circular A-133 process: the FAA ADO, the public sponsor, the sponsorâs auditor, and the DOT OIG (if a modal administration in DOT is the cognizant agency). Refer to AIP Handbook, FAA Order 5100.38C, Chapter 13, Section 3 for responsibilities. 12.6 Best Practice Recommendations: Project Reporting and Closeout 1. Review the reporting requirements and closeout procedures outlined in AIP Hand- book, Order 5100.38C, and 49 CFR 18.40. Consult with the regional ADO to verify what submittals are required. 2. Establish ongoing reporting and closeout procedures as part of the SIPâs initial work plan. Include specific tasks in the scope of work to clearly identify the FAA reporting timelines and required reports. Consider using a certified workflow process consul- tant to assist with developing these procedures. Key sponsor decision makers and consultant staff should also participate in the process. 3. Include reporting and closeout responsibilities as a separate task item within consul- tant agreements, with a separate payment provision for completing this task. 4. Use a program document management and tracking system and ensure that staff are properly trained to use it. 5. Submit all final closeout documentation to the regional ADO within 90 days of the final acceptance from the contractor. If there is a delay in closing an active grant beyond the required time period, consult with the regional ADO as soon as possible. 6. Always consult with the regional ADO regarding any questions on the reporting requirements. Use the FAA as a source of information and direction.