Period of Performance

Period of Performance and Carryover

The FFY of appropriation is the FFY for which Congress appropriated funds to the U.S. Department of Education from which the Department awards program grants, specifically the period from October 1 through September 30. For example, the FFY 2024 State Vocational Rehabilitation Services grants were made from the 2024 FFY of appropriation, which covers the period of October 1, 2023, through September 30, 2024.

The Uniform Guidance uses the term “period of performance” rather than “grant period.” Period of performance is defined in 2 CFR § 200.1 in a manner like the EDGAR definition of “grant period.” A grantee may neither obligate nor pay expenditures for costs incurred prior to the start of the period of performance. For example, the cost for VR services provided to a consumer prior to the start of the period of performance for a grant award may not be charged to that grant award. Rather, those obligations must be charged to the prior grant award. Additionally, a grantee may not obligate award funds after the end of the period of performance for a grant award.

During the FFY of appropriation, the Federal Funding Period listed in Box 6 of the GAN will be from October 1 to September 30 of that FFY. This represents the one-year period for which the award is made and in which the grantee may incur new obligations against the award. Section 19(a)(1) of the Rehabilitation Act permits grantees to carry over federal funds for obligation and expenditure in the subsequent FFY provided certain conditions are met, as described further below. This means that grantees may carry over the unobligated balance of federal funds for one FFY beyond the FFY of appropriation so long as the conditions of Section 19 of the Rehabilitation Act were satisfied.

For example, the FFY of appropriation for FFY 2023 awards began on October 1, 2022, and ended on September 30, 2023. The carryover period for FFY 2023 awards started on October 1, 2023, and ended on September 30, 2024. To carry over federal funds into the subsequent FFY for obligation and liquidation, grantees must: 
 

1. Have an unobligated balance of federal funds at the end of the FFY of appropriation (i.e., on September 30, 2023); and
2. Have satisfied the applicable non-federal share requirement by the end of the FFY of appropriation (i.e., FFY 2023) for: 
    
   1. The Federal funds obligated or liquidated during the FFY of appropriation; and
   2. The unobligated balance of federal funds to be carried over to the subsequent FFY.

Upon submission of the grantee’s 4th quarter RSA-17 (which is for the reporting period ending September 30 of the FFY of appropriation), an RSA Financial Management Specialist will review the grantee’s report to determine whether the grantee met the requirements necessary to carry over federal award funds for obligation and liquidation in the subsequent FFY. If the grantee met the requirements of Section 19 of the Rehabilitation Actto carry over funds, RSA will process an administrative change to the current GAN extending the period of performance to include the carryover period. Upon completion of RSA’s administrative action, the grantee will receive a notice of a revised GAN with the revised period of performance that includes the carryover period.

Unless the Department authorizes an extension for the carryover period consistent with the requirements of Section 19 of the Rehabilitation Act, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance, as specified on the GAN (2 CFR § 200.344(b)).

Resources

• RSA-FAQ Period of Performance for Formula Grant Awards

Obligation

Financial obligations means orders placed for property and services, contracts and subawards made, and similar transactions that require payment by a recipient under a Federal award that will result in expenditures by a recipient under a Federal award (2 CFR § 200.1). There is no authority for subawards, as defined in 2 CFR § 200.1, under the VR program, Supported Employment (SE) program and Client Assistance Program (CAP). Additionally, the future period in which obligations may be liquidated is limited by federal requirements and the terms and conditions applicable to the award. EDGAR requirements at 34 CFR § 76.707 provide additional guidance regarding when obligations are made.

For example, travel is considered obligated when the travel is taken, and personnel expenditures for State agency employees are considered obligated when the employee performs the services. In determining when an obligation is made, agencies must also follow their State laws, regulations, and policies and procedures, as applicable.

If the grantee has not met the requirements of Section 19 of the Rehabilitation Act to carry over federal funds for obligation and expenditure in the subsequent fiscal year, the grantee must incur all obligations, for which it has provided sufficient match funds, by the end of the FFY of appropriation (i.e., September 30). In this circumstance, the period of performance and the FFY of appropriation are the same. If the grantee has met the carryover requirements by the end of the FFY of appropriation, the period of performance will be extended to include the carryover period (subsequent FFY). This will enable the grantee to incur new obligations against federal award funds during the carryover period, as indicated by the revised period of performance on the Grant Award Notification (GAN). In other words, in this circumstance, the period of performance covers two FFYs – the FFY of appropriation plus the carryover year.

Resources

• RSA-PD-05-01 Liquidation of Obligations Under RSA's Formula Grants