Tens of billions of dollars are involved in a long list of grant programs that involve primary recipients making awards of federal dollars to other organizations. So, it is not surprising that the Office of Management and Budget, in its uniform guidance or so-called “Super Circular,” sought to provide clear guidance about when a “lower-tier” organization is to be treated as a subrecipient versus as a contractor. Making the correct determination when using federal funds has significant management and oversight implications.
It’s one thing if a relationship involving federal funds is being forged for the first time, but it’s quite another when the parties have been engaged with one another for years. When you look at the agreements that govern these longstanding arrangements through the prism of the revised federal guidance, the exercise can be daunting and the conclusions uncertain.
This webinar is designed to help you sort out subrecipient vs. contractor relationships, and to make decisions that are defensible, accountable and acceptable to all players. You’ll gain an understanding about:
- Differences between a subrecipient receiving federal assistance versus as a contractor being paid for goods and services.
- Distinctions between “assistance” and “procurement” relationships, and why that’s important.
- How the attributes of a relationship as cited in the federal rules are just the start of the determination.
- The role played by “determining eligibility of program beneficiaries.”
- What the federal rules mean by “responsibility for programmatic decision-making.”
- Whether the types of organizations involved has any bearing on the proper determination.
- Which federal laws and executive orders flow to subrecipients — and which ones don’t.
- Which federal laws and executive orders apply to contractors — and which ones don’t.
- How to engage in an informed dialogue with other stakeholders about your decisions.
- The oversight implications once the determination is made.
You’re probably not starting from a standing start in most of your “lower-tier” federal award relationships. Join Bob Lloyd, principal of Federal Fund Management Advisor™, to get practical help in how to realign what you have been doing with what you should be doing going forward.
Who Should Attend?
- Grant and contract managers
- Sponsored projects administrators
- Subaward administrators
- Finance directors
- Legal counsels
- Accounting staff
- Project directors
- Principal investigators
- Internal auditors
- External auditors
Hand-out Materials:
Attendees will receive presentation slides as well as access to background materials.
Allowable Charges
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).
Attend this Live Webinar and Earn up to 1.5 CPE Credits