While there is no legal limit on how many times a Federal financial assistance award can be amended to continue or renew support for a project, there are risks in funding additional project years by amending an existing award versus issuing a new award for each continuation or renewal period. The risks of funding continuations or renewals of a project by amending an existing award include:
- Reduced accountability and enforcement over time in regards to cash management, compliance and performance monitoring, and record keeping.
- Unnecessarily exposing older awards to audit and investigation findings, as amending such awards prevents us from disposing of those records as allowed by the Federal records disposition schedule
- Increasing the likelihood that obligated but unexpended funds will expire (generally no longer available for reobligation by FWS) or cancel (no longer available for expenditure by the recipient or reobligation by FWS).
To reduce or eliminate these risks, the FWS Financial Assistance Policy and Oversight (FASO) Division, Policy Branch recommends to our programs that they issue new awards each Federal fiscal year to continue or renew support for a recipient’s core mission, function or initiative. The FASO-Policy Branch expects to issue FWS policy to this effect in the future.
However, this recommendation does not prevent FWS programs from providing support for multi-year projects (projects that have an expected period of performance longer than one year; may be funded incrementally over time) or partnership agreements (cooperative agreements under which multiple activities will be developed and carried out in cooperation with the FWS; may be funded incrementally over time), as long as the FWS and recipients of such awards take measures to avoid losing funds due to funds cancellation.
Please see 'Time Limits on Financial Assistance Appropriated Funds' for more information on Federal funds availability, expiration and cancellation.