Compliance

Each recipient is responsible for developing, implementing, and monitoring award activities to provide reasonable assurance that awards are administered in compliance with financial and programmatic requirements, including the award‘s standard terms and conditions, American Recovery and Reinvestment Act (ARRA) award terms, and Special Award Conditions (SACs).

These resources provide guidance, Federal regulations, useful references and other information regarding BTOP compliance, Department of Commerce (DOC) grants policies, ARRA guidelines as well as administrative, financial, audit information, and environmental requirements.

Monitoring and Program Oversight

The requirements of the American Recovery and Reinvestment of 2009 (ARRA) demand an unprecedented level of accountability and oversight for federal programs including BTOP. As the awarding agency, it is important for NTIA to implement an effective and rigorous programmatic monitoring process that engages recipients, tracks programmatic and fiscal performance, ensures compliance, mitigates risks and issues, and demonstrates the ability to be accountable to protect taxpayer investments. The overriding goal of BTOP monitoring is to ensure that recipients are in compliance with the terms and conditions of their awards incorporated in their CD-450s; they are progressing toward successful and timely completion of their projects, and the program mitigates the potential for waste, fraud, and abuse. As part of this monitoring process, NTIA staff will perform site visits to evaluate the project's current status and identify potential areas of concern that can be corrected immediately on-site or through the development of a technical assistance plan.

BTOP Compliance

In addition to ARRA compliance requirements, each BTOP grant award recipient is subject to program-specific compliance obligations. These materials contain detailed information on these requirements and provide guidance to ensure the recipient complies with BTOP regulations.

The Notice of Funds Availability (NOFA) issued prior to each round of funding set forth the application requirements and detailed the award’s standard terms and conditions. Each recipient should only refer to the NOFA that corresponds with its award.
  • NOFA Round 1 (July 9, 2009)
  • NOFA Round 2 (January 22, 2010)
  • NOFA Round 2 limited reopening – This is an addendum to NOFA Round 2 and applies only to entities that received waiver authority from the Federal Communications Commission (FCC) to use the 763–768/793–798 Megahertz (700 MHz) public safety broadband spectrum.
For more information on BTOP compliance and ARRA reporting and compliance, refer to the following documents:
  • BTOP Compliance (November 2010) – Overview of key compliance requirements. Click the box to play video. Access a transcript of the presentation or download the slides

Award Closeout Requirements

Closeout is the process by which the National Telecommunications and Information Administration (NTIA) and Grants Office determine that the recipient has completed all applicable administrative actions and all required work. Listed below are documents that provide grant recipients with guidance regarding this process and its related requirements.

  • Award Notification Package for CCI and PCC/SBA Recipients (June 2013) -- Explains the process and provides a checklist for ensuring that all technical work and administrative requirements have been finalized to complete the BTOP award agreement between the Department of Commerce and the award recipient. Recipient can use this package as they work closely with their Federal Program Officer (FPO) and Grants Officer to verify that all final documentation has been submitted and the project is technically complete.
  • Closeout Process Webinar Notes for CCI and PCC/SBA (December 2012) – The Award Closeout Process Webinars focused on defining closeout and stakeholder roles, understanding the timing related to closeout activities, and identifying recipient closeout requirements for grant recipients. Notes from the webinars review the discussion that took place during the webinars, as well as the questions that recipients asked and responses provided by NTIA.
  • Closeout Notification Package Required Documentation
    • 424A – (PCC/SBA) Budget Information – Non-Construction Programs
    • 424C – (CCI) Budget Information – Construction Programs
    • 428 – Tangible Personal Property Report
    • 428B – Tangible Personal Property Report, Final Report
    • 428S – Tangible Personal Property Report, Supplemental Sheet
    • 429 – Real Property Status Report
    • BTOP Patent Report
  • Closeout Process Webinar for CCI Recipients (March 2013) — Overview of the process for ensuring that all funded project activities are completed, including discussions of the timing related to closeout activities and recipient closeout requirements.
  • Closeout Training Webinar for PCC/SBA Recipients (April 2013) — Overview of the process for ensuring that all funded project activities are completed, including discussions of the timing related to closeout activities and recipient closeout requirements. See the Webinar Q&A for questions and answers that were collected during this webinar.
  • Closeout Training Webinar for CCI Recipients (April 2013) — Overview of the process for ensuring that all funded project activities are completed, including discussions of the timing related to closeout activities and recipient closeout requirements. See the Webinar Q&A for questions and answers that were collected during this webinar.
  • BTOP Treatment of Property During and After Closeout Fact Sheet (March 2014) – Overview of the long-term treatment of tangible personal property (i.e., property other than real property and intangible personal property such as copyrights), and recipients’ ongoing responsibilities for these items.

Department of Commerce (DOC) Grants Policy and Guidance

Each recipient must follow certain DOC guidelines and regulations while completing its projects. These documents contain detailed information regarding DOC requirements.

ARRA Guidelines

Each BTOP recipient is required to comply with all applicable ARRA guidelines. These documents contain detailed information regarding these requirements.

Uniform Administrative Requirements

Uniform Administrative Requirements outline basic recipient requirements to receive, administer, and comply with Federal awards. Note that each recipient must follow the uniform administrative requirements applicable to its type of organization.

For commercial and non-profit organizations, hospitals, and institutions of higher education:

For state, local, and Indian tribal governments:

Financial Requirements and Cost Principles

To ensure grant funds are properly used, each recipient should become familiar with Federal regulations specifying the financial requirements and cost principles applied to all Federal grants.

Financial Requirements
Cost Principles
Note that each recipient must follow the cost principle applicable to its type of organization.



For institutions of higher education:
For state, local, and Indian Tribal governments:
For non-profit organizations:
For commercial organizations:

Audit Information

All BTOP awards are subject to audit by the Department of Commerce’s Office of the Inspector General as outlined in Office of Management and Budget’s (OMB) Circular A-133. Materials on this page provide information on Federal requirements and regulations related to audits as well as additional guidance on how the recipient can prepare for and meet audit requirements.

Environmental Compliance

All BTOP grants must comply with the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA). NEPA requires one of several possible levels of environmental review to assess environmental impacts of proposed projects funded by the award. The level of environmental review required under NEPA was determined during NTIA’s application review, and if an environmental assessment (EA) is required, details were provided in the award package.

BTOP Environmental Requirements Guidance
Pre-Award
Post-Award
Environmental Laws and Regulations
There are additional environmental laws, regulations, and Executive Branch policies that Federal agencies and recipients of Federal grant awards must comply with include the following:

Other Sites and Helpful Resources:

BTOP in Action

A Com Net crew member helps lay new fiber-optic cable lines in rural Ohio Com Net, Inc.

Com Net’s GigE PLUS Availability Coalition project deployed more than 570 miles of new fiber...

btop map logo
digital literacy logo

Connect With Us

RSS facebook flickr twitter YouTube