Unraveling OMB’s Guidance on Internal Controls for Federal Grants
§200.303 Internal controls.
The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal laws, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
This is what the U.S. Office of Management and Budget instructs federal grant recipients and subrecipients to do in its comprehensive grants management policy document that many call the “Super Circular.” The new policy sounds highly prescriptive, and it has triggered a certain amount of angst.
For most affected organizations, the first question is, “Where do I find those documents?” That one’s easy. The second question is, “What does OMB say that we should do?” The answer to that can be pretty complex. Yet another question is, “How will our auditors interpret words like effective and reasonable assurance?”
This webinar will help you respond to the OMB requirement by boiling down the prescribed internal control elements and providing practical in-depth analysis about what is required and what makes sense. Based on the recent 2016 OMB Compliance Supplement for Single Audits and its revised section on internal control, the webinar also will show you how the federal government expects auditors to assess the design and operation of your controls.
Key grant-related controls for the following activities will be discussed:
- Cash management
- Procurement of goods and services
- Safeguarding grant-acquired property
- Subrecipient management and monitoring
- Financial and performance reporting
- Time and effort reporting
- Protecting personally identifiable information
- Documentation and records management
Prerequisites: Some knowledge of federal grant management and audit requirements is helpful
Advanced preparation: None
Attendees will receive presentation slides as well as access to background documents.
BOB LLOYD is a respected authority on policies and practices affecting the award, administration and oversight of federal grants, contracts and subawards. Mr. Lloyd has more than 40 years of experience in federal award implementation. Prior to starting his management consulting practice in Washington, D.C., in 1982, he served as the executive director of the Grants Management Advisory Service and held staff positions in two large federally funded organizations. Since then, he has been a consultant, trainer or advisor to award and audit units in 16 federal award-making departments and agencies, and to recipient and subrecipient organizations and their professional advisors located in all 50 states, the District of Columbia, several U.S. territories and 18 foreign countries. He is the principal author of A Practical Guide to Federal Grants Management — From Solicitation Through Audit and several other reference works on federal grants management and audits, and currently serves as contributing editor to Federal Grants News, published by Atlantic Information Services. He also is a Charter Life Member of the National Grants Management Association and served on its Board of Directors for five years.
Who Should Attend?
- Grant and contract managers
- Sponsored projects administrators
- Finance directors
- Purchasing agents
- Legal counsels
- Federal project directors
- Principal research investigators
- Accounting staff
- Internal auditors
The costs of webinars sponsored by Federal Fund Management Advisor™ are allowable charges to your federal grants and subgrants. The cost principles issued by OMB under its uniform guidance (and applicable to all types of awardees) state, “The cost of training and education for employee development is allowable” (2 CFR 200.472).