0101 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) policies regarding the purpose, characteristics, and responsibilities pertaining to grants and cooperative agreements, hereinafter collectively referred to as “grants.”

Key points in this chapter include:

• Grants policies follow the organization of 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards;
• VA grant programs are responsible for maintaining strong internal controls over all grant activities;
• The Grants Management Service (GMS) and Office of General Counsel (OGC) will review grant regulations, Notices of Funding Opportunities (NOFO), and grant awards to ensure compliance as detailed below; and
• All grant and cooperative agreement program offices (GPOs) must implement a grantee oversight program that ensures proper administration of Federal financial assistance.

0102 Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various	Revised to align language with the updated Uniform Grant Guidance at 2 C.F.R. Part 200.	OFP	The Office of Management and Budget (OMB) released revisions to Title 2 of the C.F.R. for Federal financial assistance in April 2024, which became effective in October 2024.	April 2025
Various	Clarified the role of Grants Management Service (GMS) within the grants process at VA.	OFP	OMB included a requirement in its budget guidance that GMS review all grants-related materials prior to publication to ensure compliance.	April 2025
Various	Added reference to and role of OGC within the grants process at VA.	OFP	Updated in response to Presidential actions and OMB memoranda.	April 2025
Various	Added requirement for GPOs to ensure oversight.	OFP	Updated in response to Presidential actions and OMB memoranda.	April 2025
0104	Added references to GPOs and GMS.	OFP	These offices are referred to throughout subsequent policy chapters.	April 2025
Appendix A	Added revision history.	OFP	Reorganized chapter layout.	April 2025

0103 Definitions

2 CFR Part 200 – Federal government grants regulations, which are maintained by the Office of Management and Budget (OMB).  These regulations apply to all federal grant programs, unless exempted by authorizing statute, public law, or other federally binding enactment.

0104  Roles and Responsibilities

Office of Management, Office of Budget (OB) is responsible for the allocation of funds in accordance with the statutory authority for each grant program.

Grant Program Offices (GPO) are responsible for the management of all grant-related activities, including obtaining an Assistance Listing Number and updating Assistance Listings routinely for each grant program and the writing, development, and publication of NOFO on Grants.gov.

Head of a Grants Program Office (HGPO) has the primary responsibility for the grant program, including grant awards and administration. HGPO ensures Federal compliance with applicable statutory, regulatory, and administrative policy requirements. HGPO ensures that guidance and NOFO follow appropriate templates, include correct administrative and national policy requirements, and comply with OMB and VA regulations.  

Grants Management Staff (Program Managers)are responsible for the day-to-day management of grant programs. This includes ensuring that for grants under their purview, both Federal staff and grantees fulfill applicable statutory, regulatory, and administrative policy requirements. Program Managers are also responsible for program operations, accounting and budgeting activities (e.g., allocability, compliance with cost principles, budget monitoring, etc.), preparing NOFO and reviewing grant applications.  

Grants Management Service (GMS) is responsible for providing expertise in grant laws, regulations, and policy including drafting and updating grants policy; advising grant program offices; reporting on the VA grants portfolio; providing technical assistance and support services to the VA grants community; and collaborating with Federal partners.

Office of General Counsel (OGC) provides legal advice and services to the Secretary (SECVA) and all organizational components of the Department. OGC is responsible for completing a legal review of grant materials, including grant regulations, NOFOs, and grant awards.

Internal Controls Support Center (ICSC) is responsible for ensuring grant recipients operate within the terms of their grant through auditing, consulting, and compliance support services.

0105 Policies

010501 General Policies

1. VA GMS will ensure grants policy is updated as required when there are changes to laws, regulations, standards, or other authoritative guidance, or when new requirements dictate. This includes guidance promulgated through the United States Code (U.S.C.); Code of Federal Regulations (C.F.R.); OMB circulars, bulletins, and memoranda; Department of the Treasury guidance, and applicable VA policy. 
2. On a periodic basis, consistent with changes in Governmentwide or VA requirements, grant programs and GMS will undertake a review of all policies that are in effect to ensure that they are current and continue to reflect departmental grants management policies and priorities.
3. In general, grants policies follow the organization of the 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Policy is presented in this manner so that it closely mirrors the lifecycle of the grants process and provides staff with consistency in the arrangement of grants policies and authoritative guidance. 
4. VA will maintain strong internal controls for safeguarding assets, promoting the accuracy and reliability of financial data, and encouraging adherence to approved policies. Refer to Volume I, Chapter 5 – Management’s Responsibility for Internal Controls, and OMB Circular A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control, for additional guidance.
5. All VA grant and cooperative agreement program offices (GPOs) must implement a grantee oversight program that ensures proper administration of Federal financial assistance. VA Office of Management’s ICSC provides grantee compliance and monitoring services on a fee-basis that will reduce the risk of undetected grantee fraud, waste and abuse, and non-compliance with statutes and regulations. If ICSC is not utilized, GPOs must submit oversight plans to GMS for approval and will be required to periodically submit results to GMS to ensure VA delivers promised services to Veterans.
6. All VA GPOs must submit grant regulations, NOFOs, and grant awards to GMS and OGC for review prior to publication. GPOs are required to have OGC Procurement Law Group (PRLG) concurrence. PRLG will coordinate review with other OGC law groups, as appropriate. GMS will review materials for compliance with Presidential Executive Orders, OMB Memoranda, and 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. OGC will review materials for compliance with statutes, regulations, Presidential actions, OMB Memoranda, and other relevant guidance.
7. GMS will partner with GPOs to fulfill data requests from within or outside of VA. All VA GPOs shall promptly respond to inquiries and data calls from GMS to enable VA to carry out its responsibilities and to facilitate efficient and effective delivery of services.

0106  Authorities and References

• Title 2, Code of Federal Regulations – Federal Financial Assistance
• 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• OMB Circular A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control
• VA Financial Policy Publications
  • Volume I, Chapter 5 – Management’s Responsibility for Internal Controls

0107 Rescissions

Volume X, Chapter 1 – General Grants Policy, May 2020.

Appendix A: Previous Policy Revisions

Section	Revision	Office	Reason for Change	Effective Date
Appendix A	Removed.	OFP (047G)	No longer a specialized grants policy workflow.	May 2020
0103 Definitions	Deleted list of all grant chapter definitions.	OFP (047G)	Listing only definitions relevant to each chapter.	May 2020
Various	Reformatted to new policy format and full review.	OFP (047G)	Reorganized chapter to new layout and reviewed to mirror Vol I Ch 1.	May 2020
0101 Overview	Updated overview for clarity and uses of this policy chapter.	OFP (047G)	Clarity.	May 2016
0102 Policies	Clarified the role of GMS in the updating of policies.  Updated references to 2 CFR Part 200 where relevant.	OFP (047G)	GMS role clarification.	May 2016
0103 Authority and References	Updated to reflect current grant guidance, and to remove superseded guidance.	OFP (047G)	Updated grant guidance.	May 2016
0107 Definitions	Changes to reflect current terminology and definitions from 2 CFR Part 200.	OFP (047G)	Updated terminology and definitions	May 2016
Appendix A	Added grants policy chapter workflow as new appendix.	OFP (047G)	New grants policy chapter workflow.	May 2016