Application Tips & FAQs

Application Tips

Thank you for your interest in funding to support a preservation project in your community! In order to ensure that your proposal receives the best consideration possible, here are some suggestions from our office that you may find useful in preparing your application.
  • remember that application reviewers may not be familiar with your proposed project, so you will need describe the historic resource so that they can understand why it is important
  • clearly state what it is you want to accomplish with grant funding - a reviewer should be able to read your application and know what you are proposing
  • there must be a connection between the proposed budget and the project; every budget item should be discussed in the narrative section(s) of the application so that reviewers can understand why items are necessary
  • a longer response is not necessarily better
  • remember to answer every part of each question
  • be realistic with a proposal's timeline and remember to budget for reports and reporting requirements
  • if possible, use good photographs to illustrate your project

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Frequently Asked Questions (all grants)

An indirect cost rate agreement determines the portion of indirect costs charged to, in this case, the grant. Indirect costs are also referred to as F&A costs. F&A stands for facilities and administration. Regardless of what they are called, indirect costs are general business operations expenses incurred for a common or joint purpose benefitting more than one cost objective and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved.

Examples of common indirect costs expenses include: office space and related costs, telephone, postage, office supplies, bookkeeping services.

Administrative costs necessary to complete and administer the proposed grant cannot exceed 25% of total budget (administrative and indirect costs combined). This limitation for the Historic Preservation Fund is by statute (54 USC 302902).

Types of Indirect Cost Rates
Some applicants are eligble to use what is called a 10% de minimis rate composed of modified total direct costs (MTDC). This rate may be used indefinately. The applicability and composition of this rate is defined in 2 CFR 200. If your budget proposal includes this 10% de minimis rate, you should carefully review 2 CFR 200 to understand how to apply the rate and the types of eligible costs under it.

If your organization is ineligble to use the de minimis rate or decides to apply for an indirect cost rate agreement, then you should submit a proposal for this agreement to what is called the cognizant federal agency. The cognizant federal agency is the part of the federal government that gies you the most money. If this is the National Park Service or another part of the Department of the Interior, you may obtain an indirect cost rate from the Interior Business Center. The agreement document will be signed by both your organization and the federal agency and will usually describe the type of the rate, the effective period of the rate, and any other special notations.
Anything the grant requires is considered an eligible cost, so costs to establish and manage easements is allowable. We suggest working with your SHPO to see if they would be willing to hold the easement at a reduced cost first.

We would suggest putting this under "Other" on the budget form. Administrative costs are those involved in the direct management of the grant by you the applicant and the subgrants. This does not include program related costs like monitoring construction, creating easements, and preparing National Register nominations.
Easements will need to follow the requirements and model set out in the HPF Grants Manual. The NPS is used to working with Tribes and other groups to meet the requirements. The purpose of the easement is to protect the public investment in the site for a designated number of years. And part of that is providing public access to the grant assisted work.
As with easements, anything the grant requires can be an eligible cost. A NRHP nomination would be considered a program cost, not administrative. In most cases a consultant is hired to accomplish this task. If there were more than one property, the prime recipient could hire a consultant directly to do nominations for several subgrants. This would especially make sense if several subgrants made up a historic district and could be nominated together. Talking with your SHPO about eligibility and their NRHP process early is very important.
No, Section 106 is a program cost and not part of the administrative costs. Most of this review is handled by NPS and the SHPO. If a prime recipient has the qualifications (and the NPS approves) then the NPS may consider allowing them to conduct their own 106 reviews. The cost of conducting those reviews would fall under “personnel” for the applicant/prime recipient.
Equipment is defined in 2 CFR 200.308. Equipment is anything with a cost over $5,000 and a useful life of more than one year. An HVAC system would be part of construction costs.

Frequently Asked Questions for the Paul Bruhn Historic Revitalization Grant Program

A subgrant program is when a Federal agency provides a block of funding to an eligible applicant (prime recipient) to distribute smaller amounts of funding widely to other eligible entities to accomplish the goals of the program. The prime recipient therefore acts as the Federal agency and distributes the funding to projects in their jurisdiction.

For the purposes of the Paul Bruhn Historic Revitalization Grant Program, the applicant serves as a pass-through entity as defined in 2 CFR 200.74. The applicant (SHPO, THPO, CLG, or nonprofit) is the prime recipient and will be required to “pass through” (subgrant) funds to eligible subrecipients and ensure that all parties meet the requirements of 2 CFR 200.331, among other key requirements. The applicant must demonstrate to the NPS in their application that they are capable of fulfilling these requirements.

Example:
1. A Statewide nonprofit sees a need to preserve historic theatres in the rural areas of their State.
2. A Statewide nonprofit applies to the NPS for grant funding to preserve historic theaters. The Statewide nonprofit proposes in their application the parameters for their subgrant program, including what type of entities they will award to (nonprofits, local governments, main street organizations, individuals, etc.), how their projects will be selected, and how they will successfully manage the subgrant program.
3. The NPS awards funding to the Statewide nonprofit, making the Statewide the “prime recipient.”
4. The Statewide nonprofit publicizes its subgrant program and deadline, and then runs a competitive selection process.
5. The Statewide nonprofit then distributes funding in the form of smaller subgrants to selected rural historic theater projects in the State.
Managing a subgrant program means taking on the responsibility of the Federal agency for monitoring, payments, approvals, reporting, and closeout. It is not something to be taken lightly or not carefully planned. It is very important that the applicant demonstrate their ability to manage a Federal subgrant program and act in the role of the Federal agency in its oversight of the subgrants. Familiarity with the Office of Management and Budget’s (OMB) 2 CFR 200 will be important in making this determination. Demonstrated experience with Federal grants and management of subgrant programs will be considered.
For purposes of this program the definition of rural is set by the Bureau of the Census as populations under 50,000. Projects receiving subgrants must be located in an area with a population under 50,000. No other definitions of rural will be considered and the provided website will be considered the definitive source of information as to whether a community is considered “rural” or not.
Yes. Match is not a requirement for the Paul Bruhn Historic Revitalization Grants Program, but can be considered as a competitive factor when evaluating applications. Applicants that can demonstrate local investment through in-kind or cash match for their projects will likely have stronger applications and spread the funding further. Match may be in the form of cash, donated labor, or equipment. Other Federal funding cannot be considered as match.
No. The Paul Bruhn Historic Revitalization Grants Program is meant for prime recipients (SHPOs, THPOs, CLGs, or nonprofits) to distribute funding in subgrants to assist multiple rural preservation projects.

If you only have one site but need help, contact your SHPO, THPO, CLG, or an eligible nonprofit and ask if they have interest in applying; knowing about projects for potential subgrants may help convince an eligible prime recipient to apply.
Not necessarily. A SHPO, THPO, county-wide CLG, or nonprofit may have jurisdiction over large areas that include a mix of rural and urban communities. They may apply, but the projects must take place in the rural communities in their jurisdiction. Municipal CLGs as applicants must be rural communities and may award grants in their jurisdiction.
Grants from the Historic Preservation Fund are intended to preserve historic resources listed in or eligible for listing in the National Register of Historic Places. Projects awarded through this program should focus on the physical preservation of historic resources in support of economic development for the community. This program does not fund new infrastructure projects such as sidewalks, sewers, and water systems.

Funded subgrant projects must comply with the National Historic Preservation Act, the National Environmental Policy Act (NEPA), the relevant Secretary of the Interior’s Standards, and the Historic Preservation Fund Grants Manual.
Only tribes that have entered into a Memorandum of Agreement (MOA) with the National Park Service (NPS) to assume the duties of the SHPO may apply as a THPO. Other Federally recognized Tribes may partner with a 501(c) nonprofit to apply. The roles of the tribe and nonprofit should be well defined in the application, or spelled out in an MOA between the two parties.
Applications are due on the date stated in the grants.gov announcement.
Applicants will be given three years to complete their subgrants. Extensions may be requested and are awarded no more than a year at a time if significant progress can be shown.
No, you do not need submit financials with the application, but you should describe your ability to manage funds in relation to managing Federal subgrants. As a manger of a Federal subgrant program, you must follow the auditing and subgranting regulations in 2 CFR 200.

Audit requirements:
a) Non-Federal entities that expend $750,000 or more during a year in Federal awards shall have a single or program–specific audit conducted for that year in accordance with the Single Audit Act Amendments of 1996 (31 USC 7501–7507) and 2 CFR Part 200, Subpart F.
b) Non-Federal entities that expend less than $750,000 for a fiscal year in Federal awards are exempt from Federal audit requirements for that year, but records must be available for review or audit by appropriate officials of the Federal agency, pass–through entity, and Government Accountability Office (GAO).
The NPS considers contributing structures to a district listed in the NR like an individual listing. Yes, a district nomination could be funded but would need to involve more than one subgrant. We recommend getting a written Determination of Eligibility from your SHPO early in the process if you do not already have one.
We would expect to see a line item for "construction" that would include the total amount of funding you intend to spend on that item (roof + foundation). List them as “Subgrant construction costs” under Construction.

Same for consultant fees. List them as "Subgrant architectural services" and "Subgrant easement services" under consultant fees.
Projects cannot be pre-selected. We want to see a strong plan for a creative subgrant program that will improve resources that are significant to the community and, when rehabilitated, will contribute to local economic development. Projects might be themed (historic theatres), might involve one historic district, or might be statewide for a variety of resources.
Maybe not. This program is not designed to fund just one property. It is intended for a larger entity to apply and then give out funding to several properties. If you have just one project, speak with your SHPO, THPO, CLG, or nonprofit and ask if others are interested in applying. If the answer is no, then ask about other funding opportunities like the CLG grant program that each State runs and distributes Federal historic preservation funding at the local level.
A SHPO (or a THPO) can get involved in multiple ways. First, by distributing the opportunity to active CLGs in the state as well as nonprofit preservation partners capable of managing a subgrant program. Second, providing guidance and assistance to potential applicants by helping with determinations of eligibility for the National Register, review of draft grant applications, and providing advice on how the Secretary Standards and Section 106 work. Finally, a SHPO/THPO could also apply for funding and then subgrant out to their rural communities. A SHPO might have a state grant program that could match this funding, thereby doubling their impact within the state.
Yes, all grants from the HPF operate on a reimbursable basis, meaning the grantee spends funds first and then requests reimbursement. If there is a large expense, an advance can be requested.

We cannot fund work that happened before the start of the grant, so the Paul Bruhn Historic Revitalization Grants Program cannot reimburse previous work.
Future funding for the program is dependent on Congressional appropriations.
For NPS purposes yes, but the applicant may wish to further define who “their” subgrants would be awarded to. Perhaps only nonprofits? Or CLGs within the state? That is the design of the subgrant program that will be evaluated in the application.
Our requirements are that the subgrantee be within the primary grantee's jurisdiction, in a rural area (population 50,000 or less), and listed in or eligible for listing in the NRHP. You may not subgrant to yourself.
Not as part of this application. However, owner consent needs to happen before a subgrant is awarded.
No, they have to already be a nonprofit and IRS documentation must be provided.
As the federal awarding agency, NPS is responsible for the Section 106 and NEPA reviews of all subgrant projects. Plans and specifications for each selected subgrant project must be submitted to NPS for review.

Last updated: May 12, 2022

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