0401 Overview

This chapter establishes Department of Veterans Affairs’ (VA) financial policies for the application, review, and award of Federal financial assistance.

Key items covered in this chapter include:

• Grant Program Offices (GPOs) will determine the type of award instrument and their appropriate use, basis for funding, project periods, and distribution of non-competitive awards;
• GPOs will design and execute a merit review process for the award of discretionary grants, pursuant to 2 C.F.R. § 200.205;
• GPOs will perform a risk assessment to determine the level of risk posed (low-risk, medium-risk, or high-risk) to VA by applicants or recipients; and
• GPOs will coordinate with the Assistant Secretary for Congressional and Legislative Affairs (OCLA) to ensure members of Congress are aware of new and competing grant awards; and
• The Office of Business Oversight – Grants Management Service (OBO-GMS) and Office of General Counsel (OGC) are responsible for reviewing grant and cooperative agreements prior to publication or distribution to ensure compliance with 2 C.F.R. Part 200.

0402 Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various sections	Updated language to align with terminology used in updated 2 C.F.R. 200.	OBO- GMS (045)	Alignment with the Office of Management and Budget (OMB) revisions to Title 2 C.F.R. Part 200.	April 2026
Various sections	Added or updated citations.	OBO- GMS (045)	Added citations to provide clarity where needed and updated citations that are no longer in effect.	April  2026
Various	Clarified the role of  Office of Business Oversight – Grants Management Service (OBO-GMS) within the grants process at VA.	OFP	OMB included a requirement in its budget guidance that OBO-GMS review all grants-related materials prior to publication or distribution to ensure compliance.	April 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.	April 2026
040502	Added requirement for GPOs to allow oversight by VA’s ICSC.	OFP	Updated in response to Presidential actions and OMB memoranda.	April  2026
040503	Moved  040503 (Grant Funding and replaced with Application Review and Scoring Process	OFP	Updated layout for language and flow of subject	April 2026
	Deleted budget and finance review section	OBO-GMS (045)	Updated for language and flow of chapter	April 2026
040507	Clarified language around no-cost extensions.	OBO- GMS (045)	Updated 2 C.F.R. Part 200 clarified elements of the review process for no-cost extensions.	April 2026
040508	Added requirement for OBO-GMS review of award terms and conditions prior to issuance.	OBO- GMS (045)	OMB included a requirement in its budget guidance that OBO-GMS review all grants-related materials.	April  2026
0406	Updated hyperlinks.	OBO- GMS (045)	Updated due to invalid, incorrect, or irrelevant hyperlinks.	April  2026
040509	Added “Press Releases” to section name (Congressional Notification). Added policy statements for Funding Opportunities and Awards for VA Discretionary Grants	OBO-GMS (045)	Added policies to ensure compliance with Executive Order 14332 “Improving Oversight of Federal Grantmaking”	April 2026
040510	Changed name of section to Review Documentation and Disclosure	OBO-GMS (045)	Changed to reflect focus of section	April 2026

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

0403 Definitions

Cooperative Agreement – a legal instrument of financial assistance between VA and a recipient or a pass-through entity and subrecipient that, consistent with 31 U.S.C. §§ 6302-6305, is used to enter into a relationship with the principal purpose of transferring anything of value to carry out a public purpose authorized by a law of the United States. It shall not be used to acquire property or services for the Federal Government or pass-through entity’s direct benefit or use. A cooperative agreement is distinguished from a grant in that it provides for substantial involvement of VA in carrying out the activity contemplated by the Federal award.

Discretionary Grant – an award in which VA, in keeping with specific statutory authority that enables the agency to exercise judgment (“discretion”), selects the recipient and/or the amount of Federal funding awarded through a competitive process or based on merit of proposals. A discretionary award may be selected on a non-competitive basis, as appropriate.

Federal Award – the Federal financial assistance (grant or cooperative agreement) that a recipient receives directly from VA or indirectly from a pass-through entity including the terms and conditions set forth.

Grant Agreement –  a legal instrument of financial assistance between a Federal agency and a recipient or between a VA or pass-through entity and a subrecipient, consistent with 31 U.S.C. 6302, 6304:

Merit Review – an objective process of evaluating competing Federal award applications in accordance with written standards set forth by VA and in accordance with 2 C.F.R. § 200.205.

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.

Pass-through Entity – a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program.

Period of Performance – the time interval between the start and end date of a Federal award, which may include one or more budget periods. Identification of the period of performance in the Federal award consistent with § 200.211(b)(5) does not commit the Federal agency to fund the award beyond the currently approved budget period.

Recipient – an entity that receives a Federal award directly from VA to carry out an activity under a VA grant program.

System for Award Management (SAM) – the official U.S. Government system used for registering to do business with the Federal Government, listing contract opportunities, capturing contractor performance, viewing contract data, searching assistance listings, and reporting subcontracts. This system is accessed at SAM.gov.

0404 Roles and Responsibilities

VA Senior Appointee is responsible for establishing a process for reviewing NOFOs and discretionary grant awards and for implementing and monitoring the provisions of relevant Executive Orders (EOs). The VA senior appointee serves as the final approving authority before VA issues a discretionary grant award. The VA senior appointee is responsible for ensuring VA grants are fiscally responsible and aligned with VA and Presidential priorities. SECVA designated the Assistant Secretary for Management and Chief Financial Officer (ASM/CFO) as the VA senior appointee.

Office of Business Oversight (OBO) is responsible for ensuring that the grant program offices properly conduct administrative, financial, and compliance oversight of grants throughout their lifecycle. OBO, through Grants Management Service (GMS), is also responsible for providing expertise in grant laws, regulations, and policy; drafting and updating grants policy; advising grant program offices; reporting on VA’s grants portfolio; delivering technical assistance and support services to the VA grants community; and collaborating with Federal partners.

Grant Program Office (GPO) is responsible for programmatic administration of a particular grant program. Grant Program Office (GPO) Senior Executive is responsible for signing grant awards after approval by the VA senior appointee and ensuring grant awards comply with all applicable requirements and approved general terms and conditions. In addition, all delegated grant officials and GPOs are responsible for establishing trackable metrics and collecting data to ensure grant recipients meet required benchmarks.

Administration Senior Appointee is responsible for approving NOFOs and proposed grant awards before concurrence by OGC and the VA senior appointee.

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, NOFO, and grant awards.

Office of Congressional and Legislative Affairs (OCLA) is VA’s central point for all matters involving the U.S. House of Representatives and the U.S. Senate and is responsible for all engagement and interaction with Members of Congress, Committees of jurisdiction, and their offices.  

Reviewer is responsible for reviewing and evaluating grant applications. As part of a merit review panel, reviewers score and rank received applications. Reviewers may be subject matter experts, grants management experts, financial management of grants experts, or contribute other expertise to the review process.

0405  Policies

040501 General Policies

1. In accordance with 31 U.S.C. §§ 6301-6308 Grant Program Offices (GPOs) will determine the appropriate instrument for a Federal award (i.e., grant agreement or cooperative agreement). Grants and cooperative agreements are subject to the same rules and regulations contained in 2 C.F.R. Part 200 and this policy.
2. GPOs will comply with Executive Order (EO) 14332 “Improving Oversight of Federal Grantmaking” for all discretionary grants and will adhere to the requirements contained in Volume X, Chapter 1 – General Grants Policy, Appendix B for Awards for VA Discretionary Grants.
3. In accordance with 2 C.F.R. § 200.215, VA recipients,  and subrecipients are subject to the  guidance implementing Never Contract with the Enemy in 2 C.F.R. Part 183 which affects contracts, grants, and cooperative agreements that are expected to exceed $50,000  during the period of performance, are performed outside the United States and its territories, and are in support of a contingency operation in which members of the Armed Forces are actively engaged in hostilities.
4. All recipients/recipients must comply with Build America Buy America Act requirements, Public Law 117-58, and 2 C.F.R. Part 184, which ensures that all iron, steel, manufactured products, and construction materials are produced in the United States.
5. VA will use a grant or cooperative agreement when the principal purpose is to transfer something of value to carry out a public purpose authorized by Federal statute. The distinguishing feature between a grant and cooperative agreement is that under a cooperative agreement, substantial involvement is anticipated between a GPO and the recipient during performance of the funded activity whereas, with a grant there will be minimal involvement between the GPO and the recipient. In carrying out the activity contemplated by the Federal award, substantial involvement may include collaboration or participation by a GPO in activities specified in the award and, as appropriate, decision-making at specified milestones related to performance.
6. In accordance with 2 C.F.R. § 200.112, the  recipient or subrecipient must disclose any potential conflict of interest in writing to the GPO. GPOs will enforce VA’s conflict of interest policies to identify and manage real or potential conflicts of interest  throughout the grant lifecycle.

040502 Grants Merit Review Panel

1. In accordance with 2 C.F.R. § 200.205, for discretionary Federal awards, unless prohibited by Federal statute, each GPO must design and execute a merit review process for applications with the objective of selecting recipients most likely to be successful in delivering results based on the program objectives.
2. GPOs will consider the type and volume of applications expected to be received/reviewed and the expertise required by the reviewers when creating grant merit review panels.
3. GPOs should begin seeking review panel members prior to the application deadline. After applications are received, the GPO will convene a grant merit review panel to evaluate applications.
4. Relevant materials, including the original NOFO containing the scoring guidelines, statutes, regulations, confidentiality statements, conflict of interest statements, submitted applications, and scoring sheets must be provided to all reviewers prior to their review of applications.
5. Merit review panel members must:
   1. Be knowledgeable in the field of endeavor or subject matter under review or hold expertise in the area of grants management and or financial management of grant awards;
   2. Be sufficiently independent of the entity applying for assistance;
   3. Be able to render an objective and unbiased evaluation; and
   4. Not have a direct relationship or a personal interest in the award of Federal financial assistance to a particular applicant.
6. Reviewers shall not have or appear to have any prejudices or biases toward a particular application and must attest to no conflicts of interest prior to scoring the applications. Merit reviewers shall recuse themselves from reviewing a Federal financial assistance application if there is a real or perceived lack of independence, personal interest, prejudice, or bias towards the applicant.
7. A reviewer would be considered to have a conflict of interest in an application if that person, member of their family, friend, or previous romantic partner:
   1. Is an officer, director, trustee, partner, or employee of or consultant to the applicant organization, its parent, or any subsidiary organization;
   2. Is in current negotiations (or has arrangements concerning) with prospective employment (or other similar association) with the applicant organization, its parent, or any subsidiary organization; or
   3. Has a financial interest in the application or the applicant organization, its parent, or any subsidiary organization.

040503 Application Review and Scoring Process

1. Applications will be reviewed or scored in accordance with the evaluation criteria included in the NOFO.
2. Reviewers will individually review and score each application under consideration utilizing the written standards outlined in the NOFO. These standards should identify the number of people the agency requires to participate in the merit review process and provide opportunities for a diverse group of participants, including those representing underserved communities. The review will result in:
   1. An evaluation of all applications to ensure they meet the criteria outlined in the NOFO, including program regulations;
   2. A summary of each application’s weaknesses; and
   3. If applicable, based on GPO operating procedures, a summary of each application’s strengths.

040504 Non-Competitive Review

1. GPOs will not use the merit review process if the method for selection and award is based on a statutory, appropriation, or regulatory required formula or another non-competitive construct.
2. In addition to the above, GPOs may utilize non-competitive review processes for:
   1. Grant award extensions involving time and/or funding; or
   2. Grant programs where awards are determined through formulas.

040505 Risk Assessment

1. In accordance with 2 C.F.R. § 200.206(b)(1), VA GPOs must  establish and maintain policies and procedures for  conducting a risk assessment to evaluate the risks posed by applicants before issuing  a Federal award.
2. When conducting a risk assessment, the following are examples of items, as described in 2 C.F.R. § 200.206(b)(2), that may be considered:
   • Financial stability;
   • Management systems and standards;
   • History of performance;
   • Audit reports and findings; and
   • Ability to effectively implement requirements.
3. Pursuant to 2 C.F.R. § 200.206(a), prior to making an award, GPOs are required to review eligibility information for applicants and financial integrity information for applicants available in OMB-designated databases per the Payment Integrity Information Act of 2019 (Public Law 116-117), the “Do Not Pay Initiative” (31 U.S.C. 3354), and 41 U.S.C. 2313.
4. GPOs shall also review the responsibility and qualification records available in the non-public segment of the System for Award Management (SAM) prior to making a Federal award where the Federal share is expected to exceed the simplified acquisition threshold (See 41 U.S.C. § 2313).
   1. GPOs must consider all of the information available in SAM with regard to the applicant and any immediate highest-level owner, predecessor (meaning, an organization that is replaced by a successor), or subsidiary identified for that applicant in SAM. (See Public Law 112-239).
   2. The information in the system for a prior recipient of a Federal award must demonstrate a satisfactory record of administering programs or activities under Federal financial assistance or procurement awards, and integrity and business ethics.
   3. GPOs may make a Federal award to a recipient that does not fully meet these standards if it is determined that the information is not relevant to the Federal award under consideration or there are specific conditions that can appropriately mitigate the risk associated with the recipient in accordance with 2 C.F.R. § 200.208.
5. GPOs should consider a recipient’s compliance with Audit Requirements, subpart F of 2 C.F.R. Part 200, as applicable, to determine if there are audit findings relevant to the interest of GPOs.
6. GPOs will perform an evaluation of the adequacy of a potential recipient’s financial management practices to determine whether a potential recipient can administer Federal funds properly. This may be done through the pre-award risk assessment or by another method.
7. GPOs will determine whether the recipient has the financial capability necessary to sustain operations and perform the planned project. An intended recipient may have questionable financial capabilities if:
   • It is newly established;
   • It has never received a Federal grant award or a VA grant award; and
   • It has known financial difficulties; or there is a reasonable doubt as to its financial capabilities based on known facts or circumstances.
8. If a GPO does not make a Federal award to a non-Federal entity because the GPO determines that the non-Federal entity does not meet either or both of the minimum qualification standards as described in 2 C.F.R. § 200.206(a)(2), the GPO must report that determination to the designated integrity and performance system accessible through SAM, only if the circumstances outlined in 2 C.F.R. § 200.213(a) apply. 
9. If a GPO reports a determination that a non-Federal entity is not qualified for a Federal award, the GPO must notify the non-Federal entity as described in 2 C.F.R. § 200.213(c).
10. GPOs will inform recipients of prohibitions outlined in 2 C.F.R. § 200.216.
11. In accordance with 2 C.F.R. § 200.213(e), GPOs must not post any information that will be made publicly available in the non-public segment of the responsibility and qualification records in SAM that is covered by a disclosure exemption under the Freedom of Information Act (FOIA). If an applicant asserts within seven calendar days to the GPO that some or all of the information made publicly available in SAM is covered by a disclosure exemption under FOIA, the GPO must remove the posting within seven calendar days of receiving the assertion. Prior to reposting the releasable information, GPOs must resolve the issue with VA’s FOIA Office and submit a request via the National FOIA Portal.
12. GPOs may  impose special award conditions that correspond to the degree of risk  recipient  a means of protecting the Government’s interests and effecting positive change in the recipients’ performance or compliance post-award.
13.  Specific award conditions may be adjusted as needed based upon the recipient’s:
    1. Status in OMB-designated repositories of government-wide data (for example, SAM.gov) or review of its risk assessment (See § 200.206)
    2. History of compliance with the general or specific terms and conditions of Federal awards;
    3. Ability to meet expected performance goals and objectives designed to facilitate the delivery of meaningful results as referred to in 2 C.F.R. § 200.211;
    4. Ability to show achievement of program goals and objectives originally outlined by the program as referred to in 2 C.F.R. § 200.301; or
    5. Financial capability to perform the Federal award.
14. Specific award conditions may include one or more of the conditions contained in 2 C.F.R. § 200.208(c). Those items include but are not limited to:
    1. Requiring payments as reimbursements rather than advance payments;
    2. Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance;
    3. Requiring additional or more detailed financial reports;
    4. Requiring additional project monitoring;
    5. Requiring the recipient or subrecipient to obtain technical or management assistance; or
    6. Establishing additional prior approvals.
15. Prior to imposing specific award condition(s) as a result of a risk assessment, per 2 C.F.R. § 200.208(d), recipients must be notified, prior to the start of the Federal award, of their level of risk and of the additional requirements. Specifically the recipient must be notified of the following:
    1. The nature of the specific condition(s);
    2. The reason why the specific condition(s) are being imposed;
    3. The nature of the action needed to remove the specific  condition(s);
    4. The time allowed for completing the actions;, and
    5. The method for requesting the Federal agency or pass-through entity to reconsider imposing a specific condition.
16. Any specific condition(s) that have been imposed on a recipient by GPOs must be removed once the conditions that prompted them have been satisfied.

040506 Selection of Recipients

1. After completion of the review and in accordance with the NOFO, the individual responsible for coordinating the review (e.g., Program Official or Head of GPO) will collect reviewers’ scores, and rank the applicants’ proposals.
2. GPOs will make recommendations listing which applications should be awarded and compile this information into an award package.
3. Award packages 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, if necessary.
4. Administration senior appointees will ensure the required documents in the award package include:
   1. Completed Award Checklist. All award packages submitted for concurrence shall contain a completed award checklist signed by the GPO Senior Executive. The checklist template is maintained by OBO-GMS, and GPOs can request the most up-to-date template by emailing VAGMS@va.gov.
   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 grant agreement template. The template will be maintained by OBO-GMS. OM will obtain OGC approval on any future iterations and will publish the template for GPO use.
5. After approval by an Administration senior appointee, GPOs must submit proposed grant award packages to Office of General Counsel (OGC) and Office of Management for review and concurrence.
6. OGC will review materials for compliance with statutes, regulations, Presidential actions, OMB Memoranda, and other relevant guidance.
7. After OGC concurrence, Office of Business Oversight – Grants Management Service (OBO-GMS) will review materials on behalf of Office of Management for compliance with Presidential EOs, Office of Management and Budget (OMB) Memoranda, and 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
8. After OGC . concurrence and OBO review, OBO-GMS will assist the GPO with scheduling a meeting with the VA senior appointee seeking approval The VA senior appointee review will only occur after the GPO has obtained all other required concurrences.
9. The VA senior appointee will consider the results of the merit review panel when approving an award. The VA senior appointee may consider the application score/ranking and any other information described in the NOFO, statute, relevant EOs, or regulation.
10. 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 OBO-GMS to confirm the previously approved general terms and conditions remain sufficient.
11. In accordance with 2 C.F.R. § 200.212, GPOs will post a list of awarded applicants on USAspending.gov for public view. GPOs must also post a list of the selected recipients on their program website.
12. GPOs will notify both successful and unsuccessful applicants when a decision has been reached.
13. Grant award decisions are discretionary and not appealable by applicants unless stated otherwise in statute or regulation.

040507 Grant Funding

1. Prior to making an award, GPOs will determine, based on a budget review or cost analysis, whether the applicable budget available is sufficient to cover the allowable cost for the work to be carried out under the award.
2. GPOs will determine funding and resource requirements found in respective Federal statutes and regulations are met and funding is available prior to award.
3. VA will use the appropriation in effect at the time of award, unless a different funding method is authorized or allowed by statute or appropriation. Recipients cannot be officially selected, announced, or awarded prior to receipt of an appropriation. Notices of Funding Opportunities (NOFOs) may be issued prior to receipt of an appropriation; however, the award cannot be made until the appropriation is enacted.
4. If there is a continuation of an award, the appropriation in effect at the time the continuation is awarded will be used unless a different funding method is authorized or allowed by statute or appropriation.
5. The period of performance must be fully funded from the appropriation in effect at the beginning date of the period of performance.
   1. As VA incurs a legal liability when an award occurs, an obligation must be recorded for the entirety of the period of performance.
   2. There must be a bona fide need at the time of award.
6. An awarding office will not obligate funds for a grant in a current or future period of performance for unknown or contingent activities.
7. The terms and conditions of a grant award govern the recipient’s expenditure of funds. Therefore, the terms and conditions must address the period during which the recipient may obligate funds, how unobligated balances are to be handled, and any authorities for extending the period of availability of awarded funds.
8. Discretionary grants (including congressional earmarks) are awarded under a “project period” basis. This basis provides the recipient with an indication of the awarding office’s intent to fund the project during the approved project period.
9. In accordance with 2 C.F.R. § 200.308(a), the approved budget summarizes the financial aspects of the project or program. Recipients must submit requested deviations from the approved budget or project scope or objectives, and request prior approval as required under 2 C.F.R. § 200.308.(c).
10. VA GPOs must receive written requests with adequate justification for deviations in project budget, scope, or objectives and approve or disapprove such requests in writing. In accordance with 2 C.F.R. § 200.308(d), GPOs should typically respond to requests for deviation considerations (budget revisions or other revisions) within 30 calendar days of receipt of the request.

040508 Issuance of Grant Agreement

1. GPOs must utilize the VA-approved grant agreement template for all discretionary grant awards.
2. The template will be maintained by OBO-GMS and contains mandatory language necessary to ensure consistency across programs and continued compliance with relevant EOs.
3. GPOs may contact OBO-GMS at VAGMS@va.gov for the most up-to-date template.
4. Each grant agreement will contain information outlined in 2 C.F.R. § 200.211, which includes at a minimum:
   • Federal award performance goals;
   • General Federal award information;
   • General terms and conditions;
   • Specific terms and conditions; and
   • A statement that recipients must comply with all applicable laws, rules, regulations, and executive orders (e.g., Public Law 117-58, EO M-24-02 Build America Buy America Act, 2 C.F.R. Part 184, The National Historic Preservation Act of 1966, The National Environmental Policy Act of 1969, The Drug Free Workplace Act, etc.).
5.  The grant agreement template also includes general terms and conditions that address the following, as appropriate, whether incorporated by reference or included in whole or in part:
   1. VA and GPO administrative regulations that apply to the award;
   2. Recipient integrity and performance matters per 2 C.F.R. § 200.211(c)(1)(iii);
   3. National policy requirements per 2 C.F.R. § 200.211(c)(1)(ii);
   4. Per 2 C.F.R. § 200.211(c)(1)(iv), an indication that subsequent budget periods are subject to the availability of funds, program authority, satisfactory performance, and compliance with the terms and conditions of the Federal award, if it is anticipated that the period of performance will include multiple budget periods;
   5. The applicable cost principles based on the recipient’s organizational type (2 C.F.R. Part 200, Subpart E);
   6. The GPO’s contact information;
   7. Reporting requirements, including information such as the name of any required forms, any formatting instructions, due date(s), and submission instructions (manual or electronic) and, as applicable, a Web site for further information. This includes financial reporting, progress reporting, and, as applicable, research integrity/misconduct and invention reporting;
   8. How any program income earned under the award will be used, if appropriate;
   9. For cooperative agreements, a specific statement of the nature and extent of the awarding office’s anticipated substantial programmatic involvement in the project;
   10. The post-award requirements of applicable public policies, including protection of human subjects, and new restrictions on lobbying (38 C.F.R. Parts 16 and 45);
   11. Termination provisions; and
   12. The following statement: “The VA Office of the Inspector General (OIG) maintains a toll-free number (1-800-488-8244) for collecting information concerning fraud, waste, or abuse under grants and cooperative agreements. Information also may be submitted by web form on the OIG Hotline website or by mail to VA Inspector General Hotline (53E), 810 Vermont Ave., NW, Washington, DC 20420. Such reports are treated as sensitive material and submitters may decline to give their names if they choose to remain anonymous.”
6. The GPO must insert any additional program-specific information relevant to the award recipient into the grant agreement template. In addition to the general terms and conditions, awards may contain specific conditions, based on an analysis of factors such as past performance, risk assessment, and a review of OMB-designated repositories.
7. When applicable, the grant agreement should indicate that the recipient may assign its payments to a financial institution (bank, trust company, or other financing institution, including any Federal lending agency) if necessary, to finance the costs of the federally supported project.
8. GPOs will provide a completed grant agreement to all recipients.

040509 Press Releases and Congressional Notification

1. GPOs  must coordinate with Office of Public and Intergovernmental Affairs and Office of Congressional and Legislative Affairs (OCLA) to publish press releases and notify Congressional representatives, as required.
2. Coordination between the VA grant program and OCLA is required to ensure members of Congress receive prompt notification of all new and competing grant awards to domestic organizations. This includes significant program expansion supplements.

040510 Review Documentation and Disclosure

1. Documentation generated throughout the merit review process will be handled in a manner that protects the confidentiality of the individual reviewers’ identity, comments, and their assessment of the overall ranking.
2. ,Certain documents related to the merit review process may be made available to the public exclusive of scores and rankings, except where, in accordance with 5 U.S.C. § 552, 5 U.S.C. § 552a, and/or 5 U.S.C. §§ 1001-1014, the GPOs assert any applicable exemptions from the disclosure requirements.

0406 Authorities and References

• United States Code (U.S.C.)
• 5 U.S.C. § 552, The Freedom of Information Act
• 5 U.S.C. § 552a, Privacy Act of 1974
• 5 U.S.C. Appendix 2, Federal Advisory Committee Act (FACA)
• 31 U.S.C. §3354. Do Not Pay Initiative
• 31 U.S.C. §6301-6308, The Federal Grant and Cooperative Agreement Act (Act) of 1977
• 38 U.S.C. §309, Chief Financial Officer
• 41 U.S.C. , §2313 Database for Federal agency contract and grant officers and suspension and debarment officials
• Code of Federal Regulations (C.F.R.)
• 2 C.F.R. Part 183, Never Contract with the Enemy
• 2 C.F.R. Part 184, Buy America Preferences for Infrastructure Projects
• 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• 38 C.F.R. Part 16, Protection of Human Subjects
• Build America, Buy America Act, Pub. L. No. 117-58, §§ 70901-52
• Executive Order 12372, Intergovernmental Review of Federal Programs (as amended and supplemented)
• National Environmental Policy Act (NEPA), 42 U.S.C. §§ 4321 et seq.
• National Historic Preservation Act, 54 U.S.C. §§ 300101 et seq.
• OFP Publications Library
• OMB Memorandum M-24-02, Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure
• Public Law 116-117,  Payment Integrity Information Act of 2019
• Public Law 112-239, National Defense Authorization Act for Fiscal Year 2013
• System for Award Management (SAM)
• VA Freedom of Information Act (FOIA) Office & Portal
• VA Financial Policy Publications
  • Volume X, Chapter 1 – General Grants Policy
• VA Inspector General Hotline website

0407 Rescissions

VA Financial Policy Volume X, Chapter 4 – Grant Application Review and Award Process, May 2025.

Appendix A: Previous Revision Table

Section	Revision	Office	Reason for Change	Effective Date
040501	Realigned requirements from General Grants Policy requiring grant program offices (GPOs) to send grant NOFOs to GMS and OGC.	OFP	Realigned requirements to appropriate chapter applicable	May 2025
040511	Added language requiring compliance with Build America, Buy America Act.	OBO- GMS (045)	OMB released revisions to Title 2 of the C.F.R. adding a new part 184.	December 2023
Various	Ensured accuracy of 2 CFR citations and outlined the award process in chronological order.	OBO- GMS (045)	In previous versions the citations to 2 CFR 200 were broad and not specific.	December 2023
Appendices B-H	Appendices were removed.	OBO-GMS (045)	Appendices were moved to a practice guide available on the GMS Community of Practice SharePoint site.	December 2023
0404 Roles and Responsibilities	Updated and streamlined section.	OFP (047G)	Reorganized chapter layout	July 2022
040511	Updated to add awards must include a statement that awardees must comply with all laws, rules, regulations	OFP (047G)	Updated to address recent requirements established in OMB memorandums	July 2022
Appendix G	Removed Grant Application Rubric.	OFP (047G)	No OMB authority to support.	July 2022
Various	Reformatted to new policy format and completed 5-year review.	OFP (047G)	Reorganized chapter layout.	July 2022
Various	Updated grant application and award process for program offices.	OFP (047G)	OMB released revisions to Title 2 of the C.F.R. for Federal grants.	July 2022
0403 Definitions	Updated Definitions.	OFP (047G)	Updated and added definitions for clarity.	July 2022
0404 Roles and Responsibilities	Updated and streamlined section.	OFP (047G)	Reorganized chapter layout.	July 2022
040511	Updated to add awards must include a statement that awardees must comply with all laws, rules, regulations.	OFP (047G)	Updated to address recent requirements established in OMB memorandums.	July 2022
Appendix G	Removed.	OFP (047G)	No OMB authority to support.	July 2022
Various	Insert FAPIIS information with link and SAM information with link.	Grants Management Service (047GD)		January 2017
Various	Updated references to “grants,” “grant programs,” and “grant offices” to incorporate definition clarifications from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
Various	Included verbiage regarding types of wards from updated OMB Uniform Grant Guidance and removed references to superseded guidance.	Grants Management Service (047GD)		October 2014
Various	Updated references to “awarding office” and “grantee/recipient” to incorporate definition clarifications from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
Various	Added new OMB Uniform Grant Guidance regarding framework to evaluate applicant risk.	Grants Management Service (047GD)		October 2014
Various	Included reference that NOFA is addressed in Chapter 3.	Grants Management Service (047GD)		October 2014
Various	Updated years referenced to make funding periods generic.	Grants Management Service (047GD)		October 2014
040202  Grant Application      Review of Merit	Included the requirement of a merit review process for applicants, per OMB Uniform Grant Guidance.   Removed reference to “objective review” based upon updated guidance.	Grants Management Service (047GD)		October 2014
40202.03 Application Screening	Updated references to “funding opportunity announcement,” “grant,” and “objective review” to incorporate definition clarification from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
040202.03 C	Further clarified the definition of a conflict of interest, per OMB Uniform Grant Guidance. Updated references to “objective review” to incorporate definition clarification from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
40202.05 Conducting the Review	Updated references to “funding opportunity announcement,” “grant,” and “objective review” to incorporate definition clarification from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
40202.07 Documentation of the Review	Updated references to “funding opportunity announcement,” “grant,” and “objective review” to incorporate definition clarification from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
040203 Grant Application and Deliberate Review	Updated references to “funding opportunity announcement,” “grant,” and “objective review” to incorporate definition clarification from OMB Uniform Grant Guidance. Updated references of superseded guidance to the current guidance.	Grants Management Service (047GD)		October 2014
040204 Federal Financial Assistance Awards	Updated references to “funding opportunity announcement,” “grant,” and “objective review” to incorporate definition clarification from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
040204.02 Notice of Award	Updated to include addressing risk per OMB Uniform Grant Guidance. Updated superseded guidance to correct references.	Grants Management Service (047GD)		October 2014
0403 Authority and References	Updated all superseded guidance to the correct references.	Grants Management Service (047GD)		October 2014
Definitions	Updated references to “objective review” to incorporate definition clarification from OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014
Appendix A	Further clarified conflict of interest representation to reflect OMB Uniform Grant Guidance.	Grants Management Service (047GD)		October 2014