The Grantee )vision of Archives, Histo and Records Manage-
ment) is responsible for insuring its own compliance, and the
compliance of transferee (any public or private agency to whom
project funds are transferred for expenditure) with government-
wide requirements for the administration of Federal grants.
Federal audits conducted on behalf of this program involve in-
depth examination of grantee records to identify exceptions to
A. Conflict of Interest
No official or employee of the grantee or
transferee authorized in his official capacity
to negotiate, make, accept, or approve a con-
tract or subcontract under this program shall
have any financial or other personal interest
in any such contract or subcontract.
No person performing services for the
grantee or transferee in connection with a
project receiving Federal grant assistance
shall have a financial or other personal
interest, other than his employment, in any
contract or subcontract in connection with
the project. No officer or employee of such
person retained by the grantee or transferee
shall have any financial or other personal
interest in any real property acquired for
a funded project unless such interest is
openly disclosed in the public records of
the grantee and such person, officer or
employee has not participated in the ac-
quisition for or on behalf of the grantee or
No member of or delegate to Congress
shall be admitted to any share or part of
a grant or agreements thereunto appertaining,
or to any benefit to arise thereupon, unless
.such benefit shall be in the form of an
agreement made with a corporation for its
The grantee is responsible for enforcing
-conflict of interest policies.
B.. Equal Opportunity
Prior to the furnishing of Federal assistance,
the'grantee-shall provide the National Park Service
with an Assurance of Compliance (Form DI-1350).
Recipiem and subrecipients of F al
assistant are to be regulated by Icle 43,
Code of Federal Regulations, Subtitle A,
Part 17 (43 CFR 17). The grantee and transferree shall '
incorporate or cause to be incorporated into
.all contracts and subcontracts the applicable
equal opportunity clauses prescribed by
Title 41, Code of Federal Regulations,
Chapters 1, 14, and 14K (41 CFR Federal
The grantee and transferee shall:
1. comply or provide for compliance with the '
above provisions in work accomplished
by a grantee or transferee, including
the advance clearances provided for in
41 CFR 1.12-80501 (d) (1) (2) (3) (4);
2. ',..assist and cooperate actively with the
'National Park Service in enforcing the
.contract provisions and the rules,
regulations, and relevant orders issued
to implement the Civil Rights Laws
and Administration policies;
3. obtain and furnish to the National Park
Service such information as required
for the enforcement of equal opportunity;
4.- enforce the obligation of contractors
'and other subrecipients, including
invoking sanctions and penalties for non-
5.' refer all questionable matters of equal
*' opportunity implementation to the
National Park Service for advance
C.. Political Activity (Hatch Act)
No officer or employee of the grantee or
of a public agency whose principal employment
is in connection with any activity financed
in whole or in part pursuant to a Federal
grant shall take any part in any of the
political activities prescribed in the Hatch
* Political Activity Act, 5 U.S.C., Section 118k.
(1964), with the exceptions therein enumerated.
D. Office of Management and Budget Circular A-87
This circular, "Principles for Determining
Costs Applicable to Grants and Contracts with
State an Local Governments," appli to all
Federal distance programs. Gran-s shall
familiar Me themselves with the ci lar
and administer all phases and aspects of grant
assistance in accordance with its standards.
.Audits shall be conducted by the National
Park Service to identify exceptions.
E. Office of-Management- and Budget Circular A-95
This circular, "Regulations under.
Section 204 of the Demonstration Cities and
Metropolitan Act of.1966, Title IV of the
Intergovernmental Cooperation Act. of 1968, and.
Section.102 (2) (c) of the National Environmentdl
Policy Act of 1969," applies to all Federal
assistance programs. Grantees shall familiarize
themselves with the circular and administer
historic preservation grant assistance pro-
grams in accordance with its standards.
A paper entitled "OMB Circular A-95
(Revised): What It Is -- How It Works" has been
distributed to participants in this program.
It explains the purpose and requirements of
A-95. Grantees shall give particular attention
to requirements concerning gubernatorial review
of submissions of the State Historic Preserva-
tion Plan, and to procedures for obtaining
clearinghouse approvals of specific projects
for which grant funding is desired.
F. Office of Managementand Budget Circular A-102
'This circular, "Uniform Administrative
Requirements for Grants-In-Aid to State and
Local Governments," contains standards for
establishing consistency and uniformity among
Federal agencies in the administration of grants
to state and local governments. The circular
includes standards to insure the consistent
implementation of Sections 202,. 203, and 204
of the Intergovenmental Cooperation Act of 1968.
Policies and procedures of the historic preser-
vation grant assistance program of the National
Park Service have been reviewed and revised,
where necessary, to conform with the circular.
Grantees of the program similarly shall insure
full compliance with standards and requirements
of the circular pertaining to all aspects of
grant administration under grantee purview.
scope of the circular iluch that
it add esses virtually all aspects of grant
administration, and, as such, shall be re-
garded by the National Park Service and the
grantees as a fundamental administrative
document of this program. In certifying
compliance with National Park Service and
Federal regulations when accepting grants,
the grantee shall understand that that
certification embraces Circular A-102.
G. Contracts for Project Work
Grantees shall conform to the following
contract regulations and insure conformance
by transferees. Records for every project
shall document compliance.
1. Contracts in excess of $10,000 shall
Sbe awarded through competitive bidding,
With the exception of 2 below. The
grantee shall accept the bid promising
the best results at the most reasonable
2. Contracts in excess of $10,000 for
extensive preservation work may be
negotiated. In such cases, a
grantee shall negotiate with at
least three contractors (if that many
respond tQ advertisement), rate
each after an initial discussion,
call each back to negotiate a price,
and select the contractor that will
do the best job. Grantee records
shall include documentation pertinent
to each of the steps prescribed.
3. All bidders on contracts in excess
of $10,000 shall be informed that
Federal funds are involved.
4. Written change orders to contracts
'in excess of $10,000 shall be issued
for all necessary changes in the
project. A copy of an order shall be
made a part of the grantee project
file and kept available for audit,
and a copy shall be forwarded to
the National Park Service.
Grantees shall understand that they must
comply with state contract regulations as well
as the policies prescribed above.
Themantee and transferee sh comply with
the prove ons of the Uniform Relo ion Assistance
and Real Property Acquisition Policies Act of 1970
in administering grant-in-aid funds. The Act in-
cludes regulations governing benefits to be -
provided under .grant agreements for parties
displaced from homes and businesses as a result
of federally-assisted undertakings, and specifies
a uniform policy for real property acquisition.
I. National Environmental Policy Act of 1969
The National Environmental Policy Act
requires that every Federal agency prepare
a statement of environmental impact in
advance of each major action, recommendation,
or report on legislation that may significantly
affect the quality of the human environment.
The National Park Service prepares a pro-
grammatic statement concerning the environ-
mental impact of its'historic preservation
grant assistance effort. Once accepted by
the Department of the Interior and the
Council on Environmental Quality, the
statement will be effective for approximately
ten years. However, acceptance of the
.statement in no way lessens the responsibility
of the National Park Service and program
grantees to scrutinize all projects included
in Annual Preservation Programs as to environ-
*mental impact or potential controversy. This
scrutiny should be an integral aspect of
the historic preservation planning process.
Appropriate documentation should be
.available to support program positions
in the event of any challenge to a survey
and planning, acquisition, or development
project scheduled for grant assistance.
Acknowledging Federal Assistance
Grantees and transferees shall insure that Federal assis-
tance is acknowledged in accordance with the following guidelines:
A. Project Signs
There shall be prominently erected at every assisted
project site a sign or signs providing the information noted
below. The cost of signs, whether temporary or permanent, is
an allowable project expenditure.
1. Name of project.
2. Name of state agency administering the project,
the Division of Archives, History and Records
3. Nature of Federal assistance outlined sub-
stantially as follows:
"(Acquisition) (Restoration) (or appropriate
term) of this property, which is listed in
the National Register of Historic Places,
has been funded with the assistance of a
matching grant-in-aid from the Department
of the Interior, National Park Service,
under provisions of the National Historic
Preservation Act of 1966."
4. The sign also may include the name of the
contractor and/or architect, the project
number, the dollar amounts of state,
Federal or other sources of assistance,
and other information as appropriate. The
size and number of signs shall be adequate
to mark the site clearly and shall be in
keeping with visual esthetics of the site.
Signs shall be maintained in good condition
until work is completed under a development
project, or until six months have elapsed
following transfer of title under an
B. Public References
Public reference, (such as news releases) to
projects funded with grant assistance shall acknowledge
Federal aid substantially as follows:
"This (project) has been funded with
the assistance of a matching grant-
in-aid from the Department of the
Interior, National Park Service,
under provisions of the National
Historic Preservation Act of 1966,
in cooperation with the Department of
State, Division of Archives, History
and Records Management."