Utilities seeking to leverage federal funding through the IIJA Department of Energy (DOE) GRIP grants must adapt their existing deployment processes to meet specific DOE reporting requirements. This necessitates defining new processes, activities, and stakeholder engagement strategies to ensure compliance and effective project deployment. Read the detailed breakdown of how to meet the DOE’s requirements.

Pre-Award Negotiation Process

Upon award selection, utilities enter a negotiation period with the DOE, which can extend for several months. This phase involves discussions around project scope, risk assessments, and cost/price agreements. The complexity of the project, number of partners, and legal considerations influence the duration and depth of these negotiations.

Post-Award: Internal Reporting Compliance Stand-Up

After finalizing contracts with the DOE, utilities must establish compliance procedures adhering to DOE-mandated reporting requirements. This involves developing and maintaining grant compliance reports and documentation submitted regularly to the DOE. The introduction of federal oversight demands heightened scrutiny, transparency, and potentially shifts in responsibilities, necessitating additional training, resources, and internal policy adjustments.

Project Reporting Requirements Summary

Awarded utilities must establish a reporting compliance framework that integrates with established program management and deployment teams. Key reporting requirements include:

• Performance Report (Narrative): Quarterly submission detailing project progress
• Performance Report (Quantitative): Quarterly submission capturing quantitative project progress
• Financial Report (SF-425): Quarterly and final financial summaries
• Invoicing (SF-270): Monthly reimbursement requests
• Cybersecurity Plan: Templates for outlining project cybersecurity plans
• Project Management Plan: Defines cost, schedule, and technical performance baselines
• Special Status Report: Incident reporting as needed
• Final Report: End-of-project outcomes and milestones achieved

Community Benefits and Justice & Equity Reporting Requirements

Utilities must also report on community benefits and justice & equity metrics, including:

• Community Benefits Report: Annual progress reporting toward meeting the objectives and milestones of its community benefits plan
• Quality Jobs Creation: Weekly, annual, and final reporting on job creation and training outcomes
• Equity and Justice: Quarterly submissions detailing community engagement and diverse business participation
• Davis-Bacon Act Labor Compliance Report: Semi-annual payroll and prevailing wage compliance

Additional Reporting Needs

Utilities must disclose current and pending support, demographic information, financial conflicts of interest, personal property inventories, and file Uniform Commercial Code (UCC-1) financing statements as needed. They must also report sub-awards greater than $30,000 and submit biennial reports to Congress.

Internal Policy Compliance

Federal agencies expect utilities to have appropriate governance structures and policies to comply with federal regulations. This may require changes to existing policies or the creation of new procedures, including:

• Accounting Processes: Defining allowable costs and tracking cost sharing
• Procurement Policies: Align with FOA requirements, such as validating compliance with Buy American provisions
• Subrecipient Monitoring: Formal assignment and monitoring of subrecipients
• Documentation Frameworks: Providing trails for agency audits
• NEPA Compliance Considerations: Addressing project timing and implementation implications

Grant Deployment: Running the Federal Grant PMO

A successful award may necessitate modifying the utility’s PMO approach and structure to align with firm milestones and deadlines. Key components include:

• Program Reporting and Dashboarding: Establishing meeting cadences, KPIs, and standardized templates
• Program Governance: Developing a PMP and maintaining a master program schedule
• Internal Reporting: Aligning internal reporting processes with DOE requirements
• Program Financial Management: Monthly financial performance summaries and annual financial planning
• Program Risk, Issue, & Dependency Management: Facilitating processes and meetings to manage risks and issues
• Program Communication Management: Developing and maintaining a communication plan
• Program Schedule Management: Creating a high-level delivery plan and roadmap
• Program Quality Management: Overseeing program guidelines, lessons learned, and data quality

Conclusion

Successfully navigating DOE GRIP grants requires utilities to adopt new processes, stringent compliance measures, and robust project management frameworks. Key takeaways for ensuring successful grant execution include:

• Invest Time Upfront for Compliance Stand-Up: Dedicate resources early to meet DOE reporting requirements consistently
• Build a Federal Grant Governance Playbook: Develop comprehensive governance guidelines for all stakeholders
• Accommodate Changes to Meet DOE Requirements: Adjust internal processes, roles, and responsibilities as needed
• Perform Annual Governance Structure Refreshes: Address changes in project scope and regulatory requirements
• Invest in Supplemental Systems and Tools: Leverage technology solutions for efficient data collection and reporting

By focusing on these areas, utilities can meet DOE requirements, enhance operational efficiency, and achieve project goals. Establishing a compliance framework, aligning reporting processes, and maintaining rigorous program governance are essential to mitigate risks and ensure accountability.