Subrecipient Indirect Cost Fundamentals for Pass-Through Entities
When it started its federal grant reform initiative a couple of years ago, the U.S. Office of Management and Budget gave stakeholders multiple opportunities to suggest policy changes and raise concerns. Well, OMB heard loud and clear complaints about the practices of some pass-through entities concerning the indirect costs of their subrecipients. This led OMB to reinforce longstanding policies and initiate new ones aimed at forcing proper recognition of those costs.
The upshot of the new policies is that lots of pass-through entities are now in the indirect cost negotiation business — whether they are comfortable with this role or not. That’s because, while most of these organizations are used to formulating an indirect cost allocation plan and rate proposal that’s submitted to their federal cognizant agency, they have never been put in the position of having to review and approve the plans and rates of other organizations.
Times have changed. Subrecipients are aware of the new policies and are lining up to demand compliance with them.
This webinar has been specifically designed to help pass-through entities understand the policies and shoulder the indirect cost-related workload that they now confront. You'll learn answers to these — and related — questions:
- What are the rules that must be followed concerning subrecipients that have federally negotiated indirect cost rates?
- Who must pass-through entities negotiate with?
- What technical guidance can pass-through entities provide to their subrecipients?
- What are the steps involved in review of submitted plans and rates?
- If a pass-through entity negotiates a rate, who else must honor it?
- What are the parameters for use of the so-called de minimis rate (10% of MTDC)?
- What role will the independent auditor play in verifying indirect cost charging, and how will this help pass-through entities?
If your organization is making subawards of federal assistance, you’re bound to encounter the need to address the indirect costs of your subrecipients. This timely, practical session will prepare you to do that effectively.
Presenter Bob Lloyd, principal of Federal Fund Management Advisor, has many years of experience dealing with detailed interactions between recipients, subrecipients and federal grantor agencies.
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
- Subaward managers
- Finance directors
- Accounting staff
- Internal auditors
- External 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).