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
0104	Added Role and Responsibility for SECVA and ASM/CFO	OFP (047G)	Update to chapter for clarity	March 2026
010501	Added language to refer to new appendices	OFP (047G)	Added to clarify references	March 2026
Appendix B	Added Appendix B: SECVA Memo for Designation of Senior Appointees	OFP (047G)	Added to be referenced by other chapters	March 2026
Appendix C	Added Appendix C: Funding Opportunities and Awards process for VA Discretionary Grants Memo and Attachment	OFP (047G)	Added to be referenced by other chapters	March 2026
Appendix A	Updated previous revisions section	OFP (047G)	Follows OFP policy procedure guidelines	March 2026

For a complete list of previous policy revisions, see Appendix A.

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

Secretary of Veterans Affairs (SECVA) has delegated authority to the Assistant Secretary for Management/Chief Financial Officer (ASM/CFO) the responsibility of being the Senior Appointee for Improving Oversight of Federal Grantmaking in accordance with Executive Order 14332.

Assistant Secretary for Management/Chief Financial Officer (ASM/CFO) oversees all financial management activities relating to the Department’s programs and operations, as required by the Chief Financial Officers Act of 1990 and 38 U.S.C. §309. ASM/CFO has been delegated by the SECVA as the VA Senior Appointee responsible for overseeing funding opportunities and awards.

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. 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.
7. SECVA has delegated the ASM/CFO as the VA Senior Appointee for improving oversight of Federal grantmaking. Refer to Appendix B for official delegation.
8. In accordance with Executive Order 14332, VA developed a review and approval processes for grant funding opportunities and awards. Refer to Appendix C for details on the review and approval process

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 2025.

Appendix A: Previous Policy Revisions

Section	Revision	Office	Reason for Change	Effective Date
010501	Removed GMS and OGC review requirements not specific to chapter and realigned to appropriate grant chapters (regulations, NOFOs, and grant award reviews)	OFP	Realigned requirements not specific to chapter	May 2025
Appendix A	Moved past revisions to appendix	OFP	Realigned past revisions	May 2025
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
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

Appendix B: SECVA Memo for Designation of Senior Appointees

THE SECRETARY OF VETERANS AFFAIRS
WASHINGTON

August 26, 2025

MEMORANDUM FOR UNDER SECRETARIES, ASSISTANT SECRETARIES, AND OTHER KEY OFFICIALS

SUBJECT: Designation of the Assistant Secretary for Management and Chief Financial Officer as the Department of Veterans Affairs’ Senior Appointee for Improving Oversight of Federal Grantmaking (VIEWS 13566933)

1. DESIGNATION. This memorandum designates the Assistant Secretary for Management and Chief Financial Officer (ASM/CFO) as the Senior Appointee for Improving Oversight of Federal Grantmaking in accordance with Executive Order 14332. The ASM/CFO will implement and monitor VA grant activities to carry out the provisions of this EO.

2. AUTHORITY. Executive Order 14332,¹ Improving Oversight of Federal Grantmaking, dated August 7, 2025.

3. REFERENCES. VA Directive 0000,² Delegations of Authority and Designations and VA Financial Policy, Volume X,³ Grants Management.

4. RESTRICTIONS. VA shall not issue any new funding opportunities and awards without prior approval from the ASM/CFO.

5. REDESIGNATION. Not applicable.

6. RESCISSION. Not applicable.

7. EFFECTIVE DATE AND EXPIRATION DATE. This designation is effective upon signature and will remain in effect for 4 years from the date of execution.

/s/
Douglas A. Collins

Footnotes
¹ https://www.federalregister.gov/documents/2025/08/12/2025-15344/improving-oversight-of-federal-grantmaking
² https://vaww.va.gov/vapubs/index.cfm
³ https://department.va.gov/financiaI-poIicy-documents/#vol ume-x-grants-management

Appendix C: Updated Approval Process for New Funding Opportunity Announcements and Award Discretionary Grants

Department of Veterans Affairs
Memorandum

1. On August 7, 2025, the President signed Executive Order (EO) 14332, “Improving Oversight of Federal Grantmaking,” requiring VA to designate a senior appointee responsible for creating a process to review funding opportunities and awards for grant awards.
   
2. On August 27, 2025, the Secretary delegated to me the authority to review grant funding opportunities and awards (VIEWS 13566933).
   
3. The attached policies and procedures for approval of Notices of Funding Opportunity (NOFOs) and discretionary grant awards are effective immediately. VA Financial Policy, Volume X – Grants Management will be updated to reflect these updated requirements.
   
4. As expressly required by the EO, VA will not issue any new NOFOs or discretionary awards that do not follow the updated process, unless required by law.
   
5. Grants Management Service, in coordination with the Office of General Counsel, will maintain and publish required language for all future NOFOs and award terms and conditions. This information, along with related templates and guidance, will be available and updated on the Grants Management Service SharePoint site.
   
6. Thank you for your diligence and cooperation to help ensure accountability in VA grantmaking. If you have any questions, please contact Susie Dossie, Executive Director, Office of Business Oversight, at 202-365-1033.

/s/
Richard F. Topping

Attachments

Policies and Procedures for Funding Opportunities and Awards for VA Discretionary Grants

1. Scope and Applicability
   1. These policies and procedures are established to implement and ensure compliance with Executive Order (EO) 14332, “Improving Oversight of Federal Grantmaking.” Specifically, the EO requires agencies to designate a senior appointee responsible for creating a process to review new funding opportunity announcements and to review discretionary grants to ensure that they are consistent with agency priorities and the national interest. This guidance will be included in the VA’s Financial Policy, Volume X – Grants Management.
   2. Per the definition of discretionary grants under 2 CFR 200.1, the following grant programs and funding opportunities are subject to EO 14332:
      • Grants to States for Construction of State Home Facilities
      • Legal Services for Veterans Grants Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program
      • VA Grants for Adaptive Sports Programs for Disabled Veterans and Disabled Members of the Armed Forces (includes Equine Grants)
      • VA Homeless Providers Grant and Per Diem Program (includes Capital, Case Management, Per Diem Only, Special Needs, and Transition in Place Grants)
      • VA Supportive Services for Veteran Families Program
      • Veteran and Spouse Transitional Assistance Grant Program (VSTAGP)
      • Veterans Cemetery Grants Program
      • Veterans Legacy Grants Program
      • Veterans Transportation Program

These policies and procedures do not apply to grant programs where legislation establishes entitlement to the funds on the part of the recipient, such as block grants; those awarded based on a statutory formula; or disaster recovery grants.

2. Roles and Responsibilities
   1. Senior appointees: Individuals appointed by the President, non-career members of the Senior Executive Service, or employees encumbering a Senior Level, Scientific and Professional, or Grade 15 position in Schedule C of the excepted service.
      VA Senior Appointee: the VA Secretary designated the Assistant Secretary for Management and Chief Financial Officer (ASM/CFO) as the VA Senior Appointee responsible for creating a process for review of Notices of Funding Opportunity (NOFO) and discretionary grant awards and for implementing and monitoring the provisions of the EO. As described in Section IV and V below, the VA Senior Appointee will serve as the final approving authority before Administrations post NOFOs and issue all discretionary grants awards. The VA Senior Appointee is responsible for ensuring VA grants are fiscally responsible and align to VA and Presidential priorities.
   2. Administration Senior Appointees: As described in Section IV and V, senior appointees are either a senior advisor or political appointee within each of VA’s Administrations. An Administration Senior Appointee shall approve NOFOs and proposed grant awards before concurrence by the Office of General Counsel (OGC) and the VA Senior Appointee. They shall use independent judgment and not routinely defer to the recommendations of others.
   3. Grant Program Office (GPO) Senior Executives: GPO senior executives are delegated authority to sign grant awards after approval by the VA Senior Appointee. They have the overall responsibility to ensure their grant awards comply with the guiding principles outlined in Section III and the approved general terms and conditions are consistently applied for each award. Further, all delegated grant officials and GPOs are responsible for establishing trackable metrics and collecting information to ensure grant recipients meet the stated benchmarks. GPOs shall respond promptly to the Office of Business Oversight – Grants Management Service (GMS) and other data calls and audits inquiring about progress toward meeting benchmarks.
3. Guiding Principles
   1. GPOs, their leadership, Administration senior appointees, and the VA Senior Appointee shall adhere to the following guiding principles in preparation and review of funding opportunities and proposed awards:
      1. The activities to be funded demonstrably advance the President’s policy priorities.
      2. Awards do not fund, promote, encourage, subsidize, or facilitate:
         1. Racial preferences or other forms of racial discrimination by the grant recipient, including activities where race or intentional proxies for race will be used as a selection criterion for employment or program participation;
         2. Denial by the grant recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic;
         3. Illegal immigration; or
         4. Any other initiatives that compromise public safety or promote anti-American values.
      3. When all else is equal, preference for awards should be given to institutions with lower indirect cost rates to the extent allowable by law.
      4. Awards should be made to a broad range of recipients rather than to a select group of repeat players.
      5. Awards should include clear benchmarks for measuring success and progress toward relevant goals.
      6. As applicable, to the extent that an institutional affiliation is considered in making discretionary awards, VA will prioritize an institution’s commitment to rigorous, reproducible scholarship over its historical reputation or perceived prestige.
   2. To comply with the EO and strengthen agency accountability for grantmaking, VA will adhere to the concurrence and approval processes described in Section IV and Section V of this document.
4. NOFO Approval Steps and Requirements¹
   1. NOFOs shall be reviewed and approved by one or more Administration senior appointees prior to submitting the package for concurrence outside the Administration. Administration senior appointees may require a review by appropriate subject matter experts.
   2. After approval by an Administration senior appointee, concurrence packages shall be submitted in VIEWS to the OGC and the Office of Management (OM).
      1. Required documents in the NOFO package are:
         1. Draft NOFO.
            1. NOFOs shall align with 2 C.F.R. part 200 Appendix I, be written in plain language, and require only information necessary for the adequate evaluation of the application.
            2. NOFOs shall contain required language, as provided by GMS, aligning to guiding principles as outlined in Section III. The language will address topics to include VA’s discretion in selecting applicants for awards and specific references to Executive Orders applicable to grant recipients.
         2. Completed NOFO Checklist. Beginning October 1, 2025, all NOFO packages submitted for concurrence shall contain a completed NOFO Checklist signed by the GPO Senior Executive. The Checklist is attached to this policy and will be maintained by GMS.
   3. After OGC concurrence, GMS will assist the GPO with obtaining final approvals from the VA Senior Appointee and OMB.
      1. GPOs should plan for 10 business days for OMB’s review. If OMB does not provide a response within 10 business days, OM may determine the NOFO should proceed.
      2. The VA Senior Appointee will sign the NOFO as the designated official responsible for oversight of VA’s grantmaking program.
   4. After concurrence and signature by the VA Senior Appointee for Grants, the Administration or GPO may post the NOFO on grants.gov. GPOs shall notify GMS when NOFOs are posted.
5. Award Approval Steps and Requirements²
   1. Awards shall be reviewed and approved by one or more Administration senior appointees prior to submitting the package for concurrence outside the Administration. Administration senior appointees may require a review by appropriate subject matter experts.
   2. After approval by an Administration senior appointee, concurrence packages shall be submitted in VIEWS to OGC and OM.
      1. Required documents in the award package are:
         1. Completed Award Checklist. Beginning October 1, 2025, all award packages submitted for concurrence shall contain a completed Award Checklist signed by the GPO Senior Executive. The Checklist template is attached to this policy and will be maintained by GMS.
         2. The list of proposed awards with organization names, award amounts, and any other relevant information.
         3. Award Template (e.g., grant agreement). All discretionary grants shall use the VA-approved award template (e.g., General Terms and Conditions [GT&C]) beginning with awards entered into concurrence on or after October 1, 2025. The template will be maintained by GMS. OM will obtain OGC approval on the template and all future iterations and will publish the template for use by GPOs.
   3. After OGC concurrence, GMS will assist the GPO with scheduling a VA Senior Appointee meeting. The VA Senior Appointee review shall be last, after all other concurrences are obtained.
   4. The VA Senior Appointee will document his/her approval. Awards may then be signed and issued by delegated officials in the Administration within 30 days of the VA Senior Appointee meeting. If awards are not issued within 30 days of VA Senior Appointee approval, GPOs shall notify GMS to confirm the previously approved general terms and conditions remain sufficient.
6. Post Award Reporting
   1. Once the award is signed by the delegated official and issued to the recipients, GPOs shall report the date and aggregate awarded amounts to GMS. If only partial awards are made, GPOs shall report when the remainder of the approved grants will be awarded.
   2. GMS may require post reviews of recently executed grant awards to ensure the grant template, including general terms and conditions, was applied consistently.
7. Annual Review
   1. The VA Senior Appointee, through the GMS, will conduct the annual review required in the EO to ensure discretionary awards followed these policy requirements and are consistent with, and provide progress toward, agency priorities.
   2. In addition to the annual review required in the EO, GMS will review GPO progress in tracking and measuring recipient benchmarks as part of the annual review.
   3. OM will share findings with the applicable Administration senior appointees. Administrations shall, in turn, incorporate accountability measures for officials responsible for selecting applications and granting awards.

Footnotes
¹ This process will be used for NOFOs that enter into concurrence after August 7, 2025, unless stated otherwise in this section.
² This process will be used for awards that enter into concurrence after August 7, 2025, unless stated otherwise in this section.