0201 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policies for use in developing a new grant program.

Key points covered in this chapter:

• VA will develop regulations based on authorizing statutes;
• VA grant programs must be funded by Congress through appropriations;
• In accordance with 2 C.F.R. § 200.203, VA will maintain an accurate list of Federal programs in the Assistance Listings maintained by the General Services Administration on SAM.gov;
• Grant Program Offices (GPOs) will work with the Grants Management Service when developing regulations and submit documents to Office of General Counsel and GMS for review; and
• GPOs will establish clear goals and objectives that provide meaningful results for their programs, in accordance with 2 C.F.R. § 200.202.

0202 Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various	Updated language and information to align with April 2024 Uniform 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.	March 2026
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 or distribution to ensure compliance.	March 2026
Various	Added reference to and role of OGC within the grants process at VA.	OFP	Updated in response to Presidential actions and OMB memoranda.	March 2026
020505	Updated and deleted incorrect citations.	OFP	Prior citations no longer accurate.	March 2026
0206	Updated hyperlinks.	OFP	Hyperlinks went to outdated or removed pages.	March 2026

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

0203 Definitions

Apportionment – Distributions made by OMB of amounts available for obligation in an appropriation or fund account into amounts available for specified time periods, programs, activities, projects, objects, or any combination of these. The apportioned amount limits the obligations that may be incurred. An apportionment may be further subdivided by VA to an Administration or Staff Office. These are level two of funds control.

Appropriations – Provisions of law enacted by Congress, not necessarily in an appropriations act, authorizing the Federal agency to incur obligations and make payments for a given purpose. Usually, but not always, an appropriation provides budget authority.

Assistance Listings – Publicly available listing of Federal assistance programs, formerly known as the Catalog of Federal Domestic Assistance (CFDA), managed and administered by the General Services Administration at SAM.gov.

Assistance Listing Number – A unique five-digit number, where the first two digits represent the Funding Agency (VA is 64) and the next three digits represent the program (64.XXX) assigned to identify a Federal Assistance Listing, formerly known as the CFDA number.

Notice of Funding Opportunity (NOFO) – A formal announcement of the availability of Federal funding through a financial assistance program from a Federal agency. The NOFO provides information on the award, such as who is eligible to apply, the evaluation criteria for selecting a recipient or subrecipient, the required components of an application, and how to submit the application. The NOFO is any paper or electronic issuance that an agency uses to announce a funding opportunity, whether it is called a “program announcement,” “notice of funding availability,” “broad agency announcement,” “research announcement,” “solicitation,” or some other term. NOFOs provide information such as the type of award, eligibility requirements, evaluation criteria, and application requirements.

0204 Roles and Responsibilities

Office of Regulation and Policy Management (00REG) is responsible for assisting GPOs in the development of regulations to comply with the authorizing statute.

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 NOFOs on Grants.gov.

Office of General Counsel (OGC) is responsible for providing 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.

0205 Policies

020501 General Policies

1. In accordance with 2 C.F.R § 200.202, VA grant programs must have clear goals and objectives that facilitate the delivery of meaningful results consistent with the Federal legislation that authorized the program.
2. In accordance with 2 C.F.R. § 200.202, VA grant programs’ performance will be measured against objectives and goals developed during program planning and design. See 2 C.F.R. § 200.301 for more information on performance measurement. Performance measures may differ depending on the type of program.
3. VA grant programs’ performance plans should follow the measurement, management, and reporting requirements established by Part 6 of Office of Management and Budget (OMB) Circular A‑11 (Preparation, Submission, and Execution of the Budget; August 2022) and the Program Management Improvement Accountability Act (P.L. 114-264).

020502 Development of Regulations

1. In accordance with 38 U.S.C. § 501(d), VA will develop regulations for its grant programs.
2. GPOs must submit grant regulations to Office of Business Oversight – Grants Management Service (OBO-GMS) and Office of General Counsel (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. OBO-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.
3. GPOs are responsible for coordinating the development of regulations. Program officers will work closely with VA’s Office of Regulation and Policy Management and each Administration’s regulations office in developing regulations for a program. More information on the workflow process to have 00REG coordinate approval of new regulations and their submission to OMB is on the Office of Regulation Policy and Management, Tools for Writing VA Regulations website.
4. To facilitate the development of regulations, GPOs within the Administrations will contact their regulations office. GPOs within a Staff Office will contact 00REG.

020503 Obtaining Required Assistance Listing Number

1. The Assistance Listing Number is a five-digit number, where the first two digits represent the Funding Agency (VA is 64) and the next three digits represent the program (64.XXX).
2. OBO-GMS will aid GPOs in obtaining an Assistance Listing Number.
3. OBO-GMS will review GPO’s request for an Assistance Listing Number and coordinate submitting the following information to OMB through SAM.gov:
   1. Program Description, Purpose, Goals, and Measurement: A brief summary of the statutory or regulatory requirements of the program and its intended outcome;
   2. Identification:Identification of whether the program will issue Federal awards on a discretionary or non-discretionary basis;
   3. Projected total amount of funds available for the program: Estimates based on previous year funding are acceptable if current appropriations are not available at the time of the submission;
   4. Anticipated source of available funds: The statutory authority for funding the program and the agency, sub-agency, or specific program unit that will issue the Federal awards (to the extent possible) and associated funding identifier (for example, Treasury Account Symbol(s));
   5. General eligibility requirements: The statutory, regulatory, or other eligibility factors or considerations that determine the applicant’s qualification for Federal awards under the program (e.g., type of recipient); and
   6. Applicability of Single Audit Requirements: Applicability of Single Audit Requirements as required by subpart F.
4. GPOs must ensure all data fields are completed and meet data standardization and definitions established by OMB and the Council on Federal Financial Assistance. GPOs will ensure use of plain language in developing Assistance Listings to support communication to the public.
5. In accordance with 2 C.F.R. § 200.204(a), GPOs must include the Assistance Listing Number(s), among other information, in the NOFO. More information on NOFOs can be found in Volume X, Chapter 3 – Grant Funding Availability Announcement Process.

020504 Accounting Code

1. Prior to issuing payments to awardees of a new Federal financial assistance program, the GPO must determine the proper Accounting Classification Structure for their payment.
2. For instructions on setting up the Budget Object Class (BOC) code and cost center, reference Volume XIII, Chapter 1 – Cost Centers, Appendix B: Cost Center Request Process and Volume XIII, Chapter 2 – Budget Object Class Codes, Appendix E: FMS Budget Object Class Code Request Process, and Appendix F: iFAMS Budget Object Class Code Request Process.

020505 Grant Program Performance Measures

1. In accordance with 2 C.F.R. § 200.301(a), VA should establish program goals and objectives during program planning and design. These goals and objectives must be aligned, to the extent permitted by law, with agency strategic goals, strategic objectives, or performance goals that are relevant to the program.
2. In accordance with 2 C.F.R. § 200.301 and § 200.329, VA will clearly articulate reporting requirements such that, where appropriate, performance during the execution of the Federal award has a standard, Government-wide, OMB-approved data element against which recipient performance can be measured.
3. In accordance with 2 C.F.R. § 200.329, financial information must be monitored and reported using OMB-approved common information collections (the Federal Financial Report (SF-425)), as applicable.
4. In accordance with 2 C.F.R. § 200.301(b), GPOs will establish performance measures to not only allow them to understand the recipient progress, but also to facilitate the identification of promising practices among recipients and build the evidence upon which VA’s program and performance decisions are made.
5. Grant recipients will be required to report in accordance with the terms of the regulations and award terms and conditions (e.g., monthly, quarterly, annually), which allows the GPOs to understand the recipient’s progress.
6. In accordance with 2 C.F.R § 200.301(a), GPOs will specify how performance will be assessed in the terms and conditions of a Federal award to include the following. Potential applicants can design their projects to meet the established objectives and evaluation techniques that provide valid and reliable data on the established performance measures.
   • specific pIn accordance with 2 C.F.R. § 200.301(a), GPOs will specify how performance will be assessed in the terms and conditions of a Federal award to include:
   • specific program goals;
   • indicators;
   • targets;
   • baseline data;
   • data collection; or
   • expected outcomes (such as outputs, services performance, or public impacts of any of these) with an expected timeline for accomplishment.
   • Potential applicants can design their projects to meet the established objectives and evaluation techniques that provide valid and reliable data on the established performance measures
7. In accordance with 2 C.F.R. § 200.301(a), GPOs will:
   1. Measure the recipient’s performance to show achievement of program goals and objectives;
   2. Share lessons learned;
   3. Improve program outcomes; and
   4. Foster adoption of promising practices..
8. If available, GPOs will include a hyperlink to the reporting form to be used for the program in the Web-based version of the application package.

020506 Program Risk Assessments

1. In accordance with subchapter IV of 31 U.S.C. Ch. 33, each GPO must complete an annual improper payment risk assessment to determine the risk of significant improper payments for their program.
2. Policies regarding programmatic risk assessments are addressed in VA financial policy Volume VII, Chapter 3, Payment Integrity and Fraud Reduction. Required reviews of grantee risk assessments are covered under 2 C.F.R. § 200.206 and included in VA financial policy Volume X, Chapter 4, Grant Application Review and Award Process.

0206 Authorities and References

• Program Management Improvement Accountability Act (P.L. 114-264)
• United States Code (U.S.C.)
  • 31 U.S.C. Ch. 33, Subchapter IV-Improper Payments
  • 38 U.S.C. § 501(d), Rules and Regulations
• Code of Federal Regulations (C.F.R)
  • 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• OMB Circular A-11, Preparation, Submission, and Execution of the Budget (August 2022)
• Executive Order 11541, Prescribing the duties of the Office of Management and Budget and the Domestic Policy Council in the Executive Office of the President
• OMB Circular A-11, Preparation, Submission, and Execution of the Budget (August 2022)
• VA Plans, Budget, and Performance
• Executive Order 11541, Prescribing the duties of the Office of Management and Budget and the Domestic Policy Council in the Executive Office of the President
• Federal Financial Report, SF-425
• Public Law 114-264, Program Management Improvement Accountability Act
• VA Financial Policy Publications
  • Volume II, Chapter 2 – VA’s Budget Cycle and Fund Symbols
  • Volume VII, Chapter 9 – Payment Integrity and Fraud Reduction
  • Volume X, Chapter 3 – Grant Funding Availability Announcement Process
  • Volume X, Chapter 4 – Grant Application Review and Award Process
  • Volume XIII, Chapter 1 – Cost Centers
  • Volume XIII, Chapter 2 – Budget Object Class Codes
• VA Plans, Budget, and Performance
• Tools for Writing VA RegulationsVA St

0207 Rescissions

Volume X, Chapter 2 – Grant Program Development, May 2025

Appendix A: Previous Policy Revisions

Section	Revision	Office	Reason for Change	Effective Date
020502	Realigned requirements from General Grants Policy  requiring grant program offices (GPOs) to send grant regulations to GMS and OGC.	OFP (047G)	Realigned requirements to appropriate chapter applicable.	May 2025
0204 Roles and Responsibilities	Removing old office requirements to issue Assistance Listing numbers.	OFP (047G)	Removing old references and Office of Finance requirements.	July 2023
Appendix A	Deleted.	OFP (047G)	VA writing tools for document approval workflow is now in Authorities and References section.	July 2023
Appendix B	Deleted.	OFP (047G)	Removed CFDA template as part of process to obtain Assistance Listing Numbers from Office of Budget.	July 2023
Various	Updated section numbers throughout and changed CFDA to Assistance Listing. Numbers.	OFP (047G)	Office of Management and Budget (OMB) released revisions to Title 2 of the C.F.R. on Federal grants.	July 2023
Various	Reformatted to new policy format and completed the five- year review	OFP (047G)	Reorganize chapter layout	November 2019
0205 Policies	Updated policy statements	OFP (047G)	Properly reflect VA’s current guidelines to avoid misuse of appropriation	November 2019
020505	Updated policy statements	OFP (047G)	Changed name of office that sets up CFDA numbers to Budget Process and Data Management (041C)	November 2019