FAA Releases Updated FAQ Guidance for Coronavirus Relief Grant Programs

On March 31st, the Federal Aviation Administration (FAA) released updated frequently asked questions (FAQ) documents that provide guidance for airport sponsors on how FAA administers the $20 billion in funding that Congress made available to airports through three different coronavirus relief grant programs, including (1) the Coronavirus Aid, Relief, and Economic Security (CARES) Act Airport Grant Program ($10 billion); (2) the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), known as the Airport Coronavirus Response Grant Program (ACRGP) ($2 billion); and (3) the American Rescue Plan Act (ARPA), known as the Airport Rescue Grant Program ($8 billion). 

A brief overview of FAA's updates and links to the guidance documents are provided below. AAAE has also made separate versions of each of the three documents available that highlight FAA's revisions.

Overview of FAA's FAQ Guidance Updates. AAAE has carefully reviewed the updates to the FAQ guidance documents for all three coronavirus relief grant programs. We highly encourage airport sponsors with available funds under one or more of these programs to review the documents to ensure familiarity with the changes. We identified these five meaningful updates to the FAQs: 

• Payment Request/Reimbursement Process: The most significant change is FAA will now require that airport sponsors submit all payment requests with supporting documentation for any items identified on an invoice summary, except for payroll and debt service expenses (Q-I1, Q-I2). Examples of supporting documentation would include bills, invoices, and general ledger reports. The change applies to all three programs. This change was in response to an audit that the Department of Transportation's Office of Inspector General (DOT OIG) concluded in July 2022. In its report, the DOT OIG recommended that FAA update their policy to ensure that supporting documentation was required to mitigate the risk of improper payments. 

• Grant Closeout Reports: For all three grant programs, FAA updated its policy to require that airport sponsors submit a 'signed closeout report' instead of a 'comprehensive narrative report' in order to close out a grant for non-development expenses (Q-C1). The report must include additional details that were not previously required, such as certifications that the airport complied with all terms and conditions of the grant, including subsequent addenda; and payment requests did not include costs that were reimbursed or included as part of an Airport Improvement Program (AIP) grant as indirect, administrative, or force account costs. FAA implemented this new requirement back in June 2022 when the agency released a new sample closeout report, making this update more of a formality. 

• Airport Development Projects: Under all three grant programs, FAA permits airport sponsors to use its grant funds for airport development projects-although the scope of allowable projects is narrower under CRRSAA and ARPA-if a Development Addendum is executed. Under the updated guidance, an airport sponsor seeking to use its grant funds for a development project would be required to provide information about the 'actual costs' of the project, rather than 'estimated costs.' This applies to all three grant programs (Q-GA9 in CARES FAQ and Q-GA12 in CRRSAA and ARPA FAQs). 

• Annual Financial Reporting Requirements: For all three grant programs, FAA updated its policy to clarify the process and guidance on how to submit annual financial reporting requirements associated with CARES, CRRSAA, and ARPA grants (Q-GA16). 

• Face Mask Mandate: In CRRSAA and ARPA grant agreements, FAA included 'special conditions' that required airport sponsors to implement a policy requiring all persons to wear a mask at all times while in all public areas of airport property, except where an exemption may apply. In the updated guidance, FAA removed language that indicated failure to comply with this special condition may result in suspension of payments or termination of the grant (Q-GA17). Instead, FAA clarified that '[t]his special condition is only in effect while Executive Order 13998 is operable.' As airports are aware, in April 2022, a federal judge in Florida struck down the federal mask mandate, and the mandate is no longer in effect.  

Links to FAA's FAQ Guidance Documents and Revisions. 

• CARES FAQ Guidance: You can view the updated FAQ guidance for CARES grants here. This is the sixth iteration of the document and first update since December 3, 2020. AAAE has highlighted FAA's latest updates to the FAQ document in this version here. 

• CRRSAA FAQ Guidance: You can view the updated FAQ guidance for CRRSAA grants here. This is the fifth iteration of the document and first update since November 24, 2021. AAAE has highlighted FAA's latest updates to the FAQ document in this version here. 

• ARPA FAQ Guidance: You can view the updated FAQ guidance for ARPA grants here. This is the third iteration of the document and first update since November 24, 2021. AAAE has highlighted FAA's latest updates to the FAQ document in this version here.