Fiscal Information for IL Programs

ACL has prepared this fiscal review checklist to help Independent Living (IL) program grantees better understand the prevailing administrative and fiscal requirements for ACL awards, including the Part B and Part C awards authorized under Title VII of the Rehabilitation Act. When conducting fiscal based monitoring, ACL will utilize the topics and questions presented here to guide its review.

At the end of each Federal fiscal year, CILs are required to complete Federal Financial Reports (FFRs/SF-425s) in the Payment Management System (PMS). CIL Part C awards have a two year project period starting September 30th and ending September 29th. For each Part C award, CILs will be required to complete two FFRs: 1) an Annual FFR at the end of the first year and 2) a Final FFR at the end of second year. Therefore, when the reporting period ends on September 29th, CILs will be required to complete FFRs for two separate Part C awards. 

In recent years, ACL has awarded supplemental grants to CILs, such as the Public Health Workforce (PHWF) award. For these supplemental awards, CILs are advised to follow the specific FFR requirements in the Notice of Award as the requirements will likely vary from the standard Part C award schedule.

FFR Reporting Example – FFRs Due for the Reporting Periods Ending in September 2024

For the reporting period ending in September 2024, CIL grantees need to complete up to three FFRs as outlined below:

• FY 2022 Part C Award – For the reporting period ending September 29, 2024, CILs are required to submit a Final FFR by January 27, 2025. This Final FFR should outline the CIL’s complete financial reconciliation of the FY 2022 Part C award. All PMS draws must be completed before FFR submission. CILs are permitted an additional 120 days from the award end date to liquidate (draw) funds from PMS. The liquidation (draw) end date for this FY 2022 Part C award is January 27, 2025.
• FY 2023 Part C Award – For the reporting period ending September 29, 2024, CILs are required to submit an Annual FFR by December 28, 2024. This Annual FFR should outline the CIL’s financial reconciliation of the FY 2023 Part C award as of September 29, 2024. 
• FY 2022 Public Health Workforce (PHWF) Award – An FFR is required for the period ending September 30, 2024. The FFR type will vary based on whether a no-cost extension (NCE) was approved.
  
  • NCE Approved - For the reporting period ending September 30, 2024, CILs are required to submit an Annual FFR by December 29, 2024. This Annual FFR should outline the CIL’s financial reconciliation of the FY 2022 PHWF award as of September 30, 2024.
  • No NCE - For the reporting period ending September 30, 2024, CILs are required to submit a Final FFR by January 28, 2025. This Final FFR should outline the CIL’s complete financial reconciliation of the FY 2022 PHWF award. All PMS draws must be completed before FFR submission. CILs are permitted an additional 120 days from the award end date to liquidate (draw) funds from PMS. The liquidation (draw) end date for this FY 2022 PHWF award is January 28, 2025.

ACL OFO staff work in partnership with the Office of Independent Living Programs (OILP) to provide grant management support for the CIL awards. As part of this grant management support role, OFO staff review CIL FFRs. The CIL awards are divided into regional portfolios. Your applicable OFO contact is listed below, you can reach out to this individual with questions about FFRs, closeout, Notice of Award documents, award terms and conditions, and Uniform Guidance requirements.

• Aaron Taylor (OFO Team Lead) – aaron.taylor@acl.hhs.gov – Region 5
• Cemil Yeter – Cemil.Yeter@acl.hhs.gov – Regions 3,6, and 8
• Jessenia Falwell – Jessenia.Falwell@acl.hhs.gov – Regions 2, 4, and 7
• Jetun-Nadine Reeves - Jetun-nadine.Reeves@acl.hhs.gov – Regions 1, 9, and 10

The FFR (SF-425) form is created by the Office of Management Budget. OMB instructions for the completing the FFR (SF-425) can be accessed using this link. PMS provides general guidance on FFR completion on the following webpage - FFR Information | HHS PSC FMP Payment Management Services. The PMS automatically completes fields 1 – 9 and parts of Field 10. CILs are required to complete the remainder of Field 10 and Field 11 (as applicable). Field 12 is available for CILs to provide written comments as needed. For additional guidance and support in completing the FFR, please reach out to your assigned OFO contact.

In past reporting periods, OFO has identified some common issues with CIL FFR submissions. These issues include:

• A failure to complete fields 10e – 10h, especially field 10e. Field 10e, is the total amount of expenditures attributable to the Federal award as of the reporting period end date. The field 10e amount serves as an important component of reconciling the data provided in fields 10a and 10b.
• A failure to provide indirect cost data in field 11 or the data provided is either incorrect or incomplete. If CILs are charging indirect costs against the ACL award, then the indirect cost charges need to be reported in field 11.

When reviewing FFR submissions the OFO review team looks to ensure proper completion of fields 10 and 11. OFO staff will reach out to CILs individually with any FFR follow-up questions. OFO staff will deliver technical assistance as needed to provide additional learning on FFR reporting requirements. If you have any questions, please do not hesitate to reach out to your assigned OFO contact.