1201 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policies for the obligation of grants and cooperative agreements.

Key points covered in this chapter:

• VA will comply with 31 U.S.C. Ch. 63 to select the proper funding instrument (e.g., grants, cooperative agreements, or contracts);
• VA will comply with 2 C.F.R Part 200 for administrative requirements, cost principles, and audit requirements for Federal awards;
• VA’s transactions related to grants and similar programs are not subject to the Federal Acquisition Regulation (FAR) but are subject to 2 C.F.R. Part 200, unless stated otherwise within the program statute; and
• The use of miscellaneous vendor code is not permitted for grant obligations. Recipients must be individually vendorized.

1202 Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various	New policy	OFP	New policy	March 2026

1203 Definitions

Contract – A legal instrument by which a non-Federal recipient or subrecipient conducts procurement transactions under a Federal award. For additional information on subrecipient and contractor determinations, see 2 C.F.R. § 200.331.

Cooperative Agreement – A legal instrument of financial assistance between a Federal awarding agency or pass-through entity and a non-Federal entity that, consistent with 31 U.S.C. § § 6302–6305.

Grant Agreement – A legal instrument of financial assistance between a Federal awarding agency or pass-through entity and a non-Federal entity that, consistent with 31 U.S.C. § § 6302, 6304.

Non-Contractual obligation – Obligations with special statutory authority or other regulatory authority to exempt the obligation from Federal Acquisition Regulations (FARs) and formal acquisition procedures required by the FAR. There are instances where these obligations may be generally defined as a contract (agreement between two parties), but these obligations do not follow FAR-based procedures.

Obligation – A legally binding agreement that will result in outlays, immediately or in the future. An obligation is a legal liability of the Government against an available appropriation.

1204 Roles and Responsibilities

Administration and Staff Office Chief Financial Officers (CFOs) are responsible for ensuring the proper obligation for grants and similar programs and processing of these transactions in accordance with the guidelines in this policy.

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 Notice of Funding Opportunities (NOFOs) on Grants.gov.

1205 Policies

120501 General Policies

1. VA’s grants and similar programs include:
   1. VA Homeless Providers Grant and Per Diem Program;
   2. VA Supportive Services for Veteran Families Program;
   3. Legal Services for Veterans Grants (LSV-H);
   4. Legal Services for Veterans – Assistance with Access to VA Programs Grant (LSV-A);
   5. Veterans Cemetery Grants Program;
   6. Veterans Legacy Grant Program;
   7. Grants to States for Construction of State Home Facilities;
   8. VA Grants for Adaptive Sports Programs for Disabled Veterans and Disabled Members of the Armed Forces;
   9. Veterans Transportation Program;
   10. Staff Sergent Parker Gordon Fox Suicide Prevention Grant Program;
   11. Suicide Mortality Review Cooperative Agreements;
   12. Veteran and Spouse Transitional Assistance Grant Program (VSTAGP);
   13. Specially Adapted Housing Assistive Technology Grant Program;
   14. Accessing Telehealth through Local Area Stations (ATLAS);
   15. Food Security Grant Program; and 
   16. Dole State and Tribal Outreach Grant Program.
2. VA’s transactions related to grants and similar programs are not subject to the Federal Acquisition Regulation (FAR).
3. 38 U.S.C. § 2408 authorizes the Secretary to issue an award letter to a state to establish, expand, or improve a state Veterans’ cemetery and to make progress payments from these funds as the work is completed.
4. VA will record the obligation for grant awards on the date it is awarded.
5. Documentation required for grant programs includes, but is not limited to, the Notice of Funding Opportunity (NOFO) and the award document to the recipient.
6. Awardees selected for grant programs will be individually vendorized; the use of “Miscellaneous Vendor” is not permitted.
7. Obligations pursuant to this policy must follow the requirements for Government obligations, established in Volume III, Chapter 2 – Obligations.

120502 Integrated Financial and Acquisition Management System (iFAMS)

1. When recording obligations for grants and similar programs, a non-contractual obligation document must be used.
2. The approved document type for the obligation of Department of Health and Human Services (HHS) Non-Per Diem is OGE, Grant Obligation.
3. The payment for Department of Health and Human Services (HHS) Non-Per Diem obligations will be processed through HHS Payment Management Service (PMS) then payments transmit into iFAMS using a doc type, PGI, Grant Payment – PMS.
4. The approved document type for the obligation of Veterans Health Administration (VHA) Per Diem Grants will be OGI, Interface Grant Obligation.
5. The electronic funds transfer (EFT) payment for Veterans Health Administration (VHA) Per Diem Grants obligations will be processed through Invoice Payment Processing System (IPPS).

120503 Financial Management System (FMS)

1. When recording obligations for grants and similar programs, a miscellaneous obligation document (e.g., 1358) must be used.
2. Approved use / authority code 20 and sub-authority E must be used when recording the obligation in FMS.
3. Payment will follow the IPPS or HHS PMS, depending on the award.

1206 Authorities and References

• United States Code
  • 15 U.S.C. § 3710a
  • 31 U.S.C. § 6101(3)
  • 31 U.S.C. Ch. 63, Using Procurement Contracts and Grant and Cooperative Agreements
  • 38 U.S.C. Ch. 20, Benefits for Homeless Veterans
  • 38 U.S.C. § 2408, Aid to States, counties, and tribal organizations for establishment, expansion, and improvement of veterans’ cemeteries
  • 38 U.S.C. Ch. 81, Subchapter 3, State Home Facilities for Furnishing Domiciliary, Nursing Home, and Hospital Care
• 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, And Audit Requirements For Federal Laws 
• 2 C.F.R. Part 802, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• VA Financial Policy Publications
  • Volume III, Chapter 2 – Obligations
• Grants.Gov

1207 Rescissions

None.

Appendix A: Previous Policy Revisions

None.