Government Grants: Program-Specific Compliance

Venable’s federal grants attorneys advise clients across industries on the unique federal grant compliance requirements that arise under federally funded programs, offering practical guidance tailored to specific sectors such as infrastructure, disaster response, research, and social services.

Our team has several decades of experience in supporting clients across a variety of industries and offering counsel on the various program-specific considerations that arise in federally supported projects. We have assisted clients with a myriad of infrastructure/construction projects, disaster response, conservation, foreign aid, healthcare, and research.

We provide program-specific compliance guidance across a wide range of federally funded initiatives and emerging federal policy mandates, helping clients understand and meet the distinct requirements that apply in various areas.

Guidance On Program-Specific Compliance Requirements Across Federally Funded Programs

In the context of infrastructure, construction, and disaster funding, we commonly advise clients on:

  • Real property issues, including federal interest, fair market assessment, cost allowability, property disposition, and other related issues
  • Construction matters, which include health and safety requirements, as well as prevailing wage (both federal and state) requirements, such as the Davis Bacon Act and little Davis Bacon Acts
  • Domestic sourcing requirements, including Build America, Buy America (BABA) Act requirements and similar pre-existing requirements most commonly applicable to Department of Transportation (DOT) funding
  • Small Business and Disadvantaged Business Enterprise (DBE) sourcing under 2 C.F.R. § 200.321, as well as more specific requirements for DOT programs under 49 C.F.R. Part 26 and Environmental Protection Agency (EPA) programs under 40 C.F.R. Part 33
  • Disaster response programs under the Stafford Act, including preparing sole-source justifications for exigent procurements, in addition to assisting in all facets of designing and implementing rebuilding programs under the Department of Housing and Urban Development’s (HUD) Community Development Block Grant program

In the context of federally supported research, we advise our clients on:

  • Intellectual property requirements, including licenses claimed by federal funders in copyrightable works and patentable inventions, under the Bayh Dole Act, 35 U.S.C. § 200 et seq., 2 C.F.R. § 200.315
  • Human subjects protections, including notice and consent obligations, privacy/data protection requirements, as well as planning for and mitigating potential liabilities thereunder
  • Strategic considerations and agreement terms in collaborative efforts funded via Federally Funded Research and Development Centers (FFRDCs) or coordinated with Federal laboratories under Cooperative Research and Development Agreements (CRADAs)

Finally, responding to an ever-evolving compliance environment, addressing issues such as:

  • Terms and conditions arising from Executive Orders 14151 and 14173, emphasizing nondiscrimination in federal programs
  • Evolving interpretations of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), 8 U.S.C. § 1611 et seq., as applied to federally supported social service providers

Representative Matters
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  • Assisted a nationally recognized university in developing pre-position procurements with various contractors, including robust document retention policies, to ensure compliance with federal requirements under the Stafford Act and related FEMA funding in the event of future natural disasters
  • Provided domestic preference analyses for a large multinational for-profit entity working under federal grant programs. Analyses have included Buy American Act, Trade Agreements Act, DOT’s and its subagencies’ Buy America Act, BABA, as well as other agency-specific domestic preference requirements
  • Provided BABA analysis for a port contractor procured under various federal funding programs for large industrial materials and equipment. In some instances, assisted in negotiating with higher-tiered parties on the applicability of BABA, the application of public interest waivers, and other requirements
  • Advised numerous clients, either rebuilding under FEMA-funded activities or improving green infrastructure under the Inflation Reduction Act and/or the Infrastructure Investment and Jobs Act, on the application of DBA
  • Advised a large nonprofit client that is funded by federal, state, and city funders on evolving federal and state requirements related to DBE participation, including potentially conflicting requirements
  • Assisted multiple clients with Title VI policies meeting DHS-specific expectations
  • Assisted a local government entity in navigating procurement through cooperative purchasing under federal General Services Administration (GSA) schedule contracts
  • Assisted a nonprofit grant recipient in the healthcare sector in navigating updated state-level guidance on PRWORA requirements