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SF-270 Request for Advance or Reimbursement: When to Use It and How to Prepare It From Grant Ledgers

SF-270 Request for Advance or Reimbursement: When to Use It and How to Prepare It From Grant Ledgers

Last updated: October 17, 2026 · Independent guide · We do not sell rankings or coverage.

The SF-270, Request for Advance or Reimbursement, is the government-wide form a federal award recipient uses to ask for cash on a non-construction award when the agency does not pay through an electronic drawdown system such as Treasury’s ASAP or HHS’s Payment Management System (PMS). You use the same SF-270 to request an advance of expected cash needs or reimbursement of costs you have already paid, and the figures on it come from cumulative grant-coded outlays in your general ledger.

The SF-270 process at a glance

  1. Confirm the payment method and form your award requires.
  2. Choose advance or reimbursement, and cash or accrual basis.
  3. Close the period and pull cumulative grant-coded outlays from the general ledger.
  4. Deduct program income and split the federal and non-federal shares.
  5. For advances, apply the cash-on-hand test.
  6. Complete, certify and submit the form with the agency’s supporting schedule.
  7. Record the receivable and receipt, then reconcile to the SF-425 and the award ledger.
Stage Responsible Accountable / approves Consulted or informed
1. Confirm method and form Grant accountant Finance director or controller Program manager; agency grants officer
2. Advance or reimbursement Grant accountant Finance director Treasury or cash manager
3. Pull outlays from GL Grant accountant Controller Payroll, AP
4. Program income and shares Grant accountant Controller Program manager (match records)
5. Cash-on-hand test Grant accountant Finance director Cash manager
6. Certify and submit Grant accountant (preparer) Authorized certifying official Agency grants office
7. Record and reconcile Staff accountant Controller Auditors at year end

Illustrative role assignment.

When agencies require the SF-270 instead of PMS or ASAP

Under 2 CFR 200.305(b), federal agencies must use OMB-approved, government-wide information collections when recipients request payment (eCFR, 2 CFR 200.305, current as of October 15, 2026). The SF-270 is one of those collections. EPA describes it as the form for advances or reimbursement on “all non-construction programs” (EPA, October 6, 2026). Construction awards use the SF-271, Outlay Report and Request for Reimbursement for Construction Programs (OMB 4040-0011, expiring June 30, 2028, per the EDA copy of the form, no date shown).

Many agencies pay electronically instead. In Treasury’s ASAP, recipients “request payments from these pre-authorized accounts” online (Bureau of the Fiscal Service, October 15, 2026). NIH and other HHS components pay through PMS (NIH Grants Policy Statement, revised March 2026).

The SF-270 remains where the agency reviews each request before paying, and agency pages show both patterns:

  • USDA FPAC: NRCS, RMA and FPAC-BC agreements “use the SF-270,” and FSA agreements use it when the manual submission box in field 19 of the award document is checked (FPAC Business Center, no date shown).
  • Agencies that have moved away: the National Park Service says the SF-270 “is no longer required” with reimbursement requests and recipients draw through ASAP after approval (NPS, May 5, 2025). The State Department’s ECA bureau moved new awards to PMS, which it said “eliminates the use of the SF 270” (ECA archive, no date shown).

Your award document decides the method, so check it before every new award.

Stage 1: Confirm the payment method and form

Owner: grant accountant. Inputs: notice of award, terms and conditions, agency payment page. Output: a one-line payment profile in the grant file (method, form, submission channel, frequency, advance limit).

Use the current form. The SF-270 is OMB 4040-0012, and current agency copies show an OMB expiration date of June 30, 2028 (PHMSA SF-270 instructions, no date shown). Agencies also set their own rules on top of the form. FPAC, for example, says advance periods are “normally 30 to 60 days” and that requests for more than 60 days may be rejected (FPAC payment request guide, no date shown).

Stage 2: Choose advance or reimbursement

Owner: grant accountant. Output: Items 1 and 2.

Under 2 CFR 200.305(b)(1), you may be paid in advance only if you keep written procedures and financial systems that limit advances to “the minimum amounts needed” and time them to actual, immediate cash requirements. Reimbursement is preferred when you cannot meet those conditions, when the agency imposes a specific condition, when you ask for it, and for construction awards. The agency must pay a reimbursement request within 30 calendar days unless it reasonably believes the request is improper (eCFR, October 15, 2026).

The form instructions say “all requests for advances shall be prepared on a cash basis” (PHMSA fillable SF-270 with instructions, older version expiring January 31, 2025). AMS rejects a single SF-270 that requests both an advance and a reimbursement, so submit two forms if you need both (AMS, no date shown).

Stage 3: Pull cumulative outlays from the grant-coded GL

Owner: grant accountant. Inputs: trial balance filtered by the grant’s fund, project or grant dimension, payroll distribution, AP subledger. Output: Line 11a, total program outlays to date.

Line 11a is cumulative from the start of the award, not the activity for the period. On a cash basis, outlays are cash disbursements plus indirect costs charged, the value of in-kind contributions applied and cash advances to subrecipients and contractors, all net of refunds, rebates and discounts. On an accrual basis, you add the net change in amounts owed (PHMSA SF-270 instructions). Your chart of accounts therefore needs a grant or project segment that tags every cost, including match and in-kind entries, to the award. That coding also supports the 2 CFR 200.302(b)(3) requirement to keep records that identify the amount, source and expenditure of federal funds (eCFR, 2 CFR 200.302, October 15, 2026).

Controls: close payroll and AP before running the report, post indirect costs at your NICRA or de minimis rate, and check cost dates against the period of performance. What goes wrong: reporting period activity instead of cumulative totals, and a missing indirect entry.

Stage 4: Deduct program income and split the shares

Owner: grant accountant. Output: Lines 11b through 11i.

Line 11b is cumulative program income, but only income the award terms require you to use on the project. Line 11c is net outlays (11a minus 11b). Line 11d is used only for advances. Line 11e is 11c plus 11d. Line 11f is the non-federal share, Line 11g the federal share, Line 11h the federal payments previously requested, and Line 11i the federal share now requested (11g minus 11h). FPAC checks that Line 11h equals Line 11g on your prior SF-270 (FPAC guide).

Worked request (illustration). A county runs a $400,000 non-construction award with a 75% federal share and 25% required match. It requests reimbursement on a cash basis for July 1 to September 30, 2026. Its grant-coded ledger, including match-coded costs, shows the following cumulative totals since the award began.

GL source (cumulative to September 30, 2026) Amount SF-270 line
Salaries and fringe benefits $237,120 11a
Travel, supplies and contractual $57,630 11a
Indirect costs charged $30,250 11a
Total program outlays to date $325,000 11a
Program income required to be used on the project ($5,000) 11b
Net program outlays $320,000 11c and 11e (11d is zero)
Non-federal share at 25% $80,000 11f
Federal share at 75% $240,000 11g
Federal payments previously requested (prior SF-270s) $171,000 11h
Federal share now requested $69,000 11i

Before submitting, the accountant confirms that match-coded costs are at least $80,000; otherwise Line 11g is overstated. All figures in this example are illustrative.

Stage 5: Apply the cash-on-hand test to advances

Owner: grant accountant with the cash manager. Output: Line 11d, or Item 12 if the agency uses the alternate computation.

The rule is 2 CFR 200.305(b)(1): advances are limited to the minimum needed and timed to immediate cash requirements. Agencies translate it into day counts. NIH tells recipients to draw “no more than 3 business days before the funds are needed” (NIH, March 2026). DOJ says federal cash on hand should be the minimum needed for disbursements made immediately or within 10 days, and that funds not spent within 10 days must be returned (DOJ Grants Financial Guide, last updated December 2025).

Item 12 makes the test explicit: estimated federal cash outlays for the advance period (12a), less the estimated balance of federal cash on hand at the start of the period (12b), equals the amount requested (12c). Agencies may require either Item 11 or Item 12, but not both (PHMSA SF-270 instructions).

Illustration: a nonprofit has received $410,000 in federal advances and has paid $396,500 of federal-share costs, so federal cash on hand is $13,500. Next month’s federal-share payroll and vendor payments are estimated at $58,000. The request is $58,000 minus $13,500, or $44,500. Compute cash on hand from the ledger, not the bank balance, because a pooled account holds other money.

Excess cash has a cost. Advances generally belong in interest-bearing accounts, and interest above $500 a year must be remitted to PMS, while recipients may keep up to $500 for administrative expenses (2 CFR 200.305(b)(11) and (b)(12)).

Stage 6: Certify and submit with support

Owner: preparer, with the authorized certifying official signing Item 13. Output: signed form plus supporting schedule.

The signer certifies that the data are correct and the payment is due and not previously requested. AMS checks that a reimbursement certification is dated on or after the Block 8 end date, and that an advance certification is dated before the Block 8 start date (AMS). Support varies: FPAC wants a Budget Expense Table, while AMS expects a cost summary by category, personnel hours and rates, and equipment invoices. What goes wrong: a Block 8 period that overlaps an earlier request without an explanation of why those costs were not billed before, and Lines 11j or 12 completed when the agency wants them blank.

Stage 7: Record the receivable and reconcile

Owner: staff accountant, reviewed by the controller. Output: grant receivable or deferred revenue entry, and a drawdown log.

For a reimbursement, book a grant receivable for the Line 11i amount when you submit and clear it when cash arrives. For an advance, record the receipt as a refundable advance or deferred revenue until you spend it. FPAC requires a budget expense table showing actual spending within 30 days after an advance period ends, and it will not process a new request until prior advances are at least partly liquidated. Each quarter, tie cumulative federal requests to the cash receipts on your SF-425 Federal Financial Report, and at year end tie expenditures to your schedule of expenditures of federal awards.

Metrics to track

  • Days from period end to submission: a long lag means you finance federal costs with your own cash.
  • Days from submission to payment: compare to the 30-day payment requirement for reimbursements in 200.305(b)(3).
  • Rejection rate and reason: track returned forms by cause (dates, Line 11h mismatch, missing support).
  • Federal cash on hand at month end: by award, measured against the agency’s day limit.
  • Unliquidated advances: amount and age by award.
  • Interest earned on federal advances: year to date against the $500 retention limit.

How software supports each stage

A fund accounting system or ERP does most of Stages 3, 4 and 7 if every transaction carries a grant code. Sage Intacct’s Grant Tracking and Billing lets you “tag select financial transactions with specific grant information for reimbursement requests” and track ALN data for the SEFA, depending on your subscription (Sage Intacct documentation, October 8, 2026; Sage sells the product). MIP Accounting, from Momentive Software, lists a multidimensional chart of accounts and grant reporting in its core package (MIP, no date shown; the vendor sells the product). Neither vendor page says it completes the SF-270 itself, so plan on a report that produces Lines 11a through 11i and copying the figures into the agency form.

Stages 1, 2, 5 and 6 are review steps that software supports only through approval workflows and cash forecasts. Our guide to grant management software covers tools that sit beside the ledger.

How we researched this

We read 2 CFR 200.302 and 200.305 on eCFR, current SF-270 and SF-271 form copies and instructions, and payment guidance from EPA, USDA FPAC, USDA AMS, NIH, DOJ, the National Park Service, the State Department and Treasury’s Bureau of the Fiscal Service, checked between October 15 and October 17, 2026. The pages that rank for this term are mostly blank agency PDFs and field instructions, so we added the ledger mapping, cash-on-hand calculation and reconciliation steps they omit.

Related guides

Frequently asked questions

Do I need an SF-270 if I draw funds through ASAP or PMS?

Usually not. ASAP and PMS take the request electronically, so you need the form only if your award terms ask for it.

Can I request an advance and a reimbursement on the same SF-270?

The form has both boxes, but some agencies reject combined requests. AMS says one SF-270 should not include a request for both, so submit separate forms. Advances must always be on a cash basis.

Is Line 11a for the period or cumulative?

Line 11a is total program outlays to date, so it is cumulative from the start of the award. The current request is derived by subtracting prior federal payments (Line 11h) from the cumulative federal share (Line 11g).

How much federal cash can I keep on hand after an advance?

Only the minimum needed for immediate disbursements, under 2 CFR 200.305. NIH allows draws up to three business days ahead, DOJ uses 10 days and USDA FPAC normally allows 30 to 60 day advance periods.

What happens to interest earned on a federal advance?

You may keep up to $500 a year of interest earned on federal funds for administrative expenses. Interest above $500 must be returned to the HHS Payment Management System, regardless of which agency paid you.

Sources

Sherman Hsieh

CEO & Editor-in-Chief, Business-Software.com
Independent analysis of enterprise software — ERP, CRM and more
Sherman Hsieh is the founder, CEO, and editor-in-chief of Business-Software.com. He leads the site's independent, buyer-focused coverage of ERP, CRM, and other business systems, including vendor-neutral comparisons, pricing analysis, and implementation guidance. Before founding Business-Software.com, Sherman was an executive at Siebel ...