What Subrecipients Need to Know About Federal Grant Rules
Few grants management topics have received as much attention over the last couple of years as subrecipient management and monitoring. When the U.S. Office of Management and Budget rolled out its new “Super Circular” reforming longstanding federal policies, it hung a big light on the duties and responsibilities of “pass-through entities” — organizations that provide subawards (subgrants) to subrecipients. It instructed them to engage in a host of specific pre-award due diligence activity and post-award oversight actions.
There’s little question that most pass-through entities have taken OMB’s instructions seriously. But some pass-through organizations, it appears, may be introducing requirements and practices into subaward relationships that go beyond both the letter and spirit of the federal requirements. Short of picking fights that can seriously damage important but fragile funding relationships, what is a subrecipient to do about subaward policies that are objectionable or flat-out wrong?
This webinar has been designed to identify the policy areas where such problematic issues arise. And, relying on key elements of OMB’s “Uniform Guidance,” it will help you craft strategies to seek and effectively trigger reconsideration and revisions. It will address:
- Requirements for advance payment of subrecipients
- Undue restrictions on indirect cost recovery
- Improper restrictions on how subrecipients can meet matching or cost sharing
- Introduction of additional prior approval requirements
- Imposition of pass-through entity organizational travel policies to subrecipients
- Restrictive interpretations of federal cost principles on employee compensation
- Pass-through agency review of subrecipient procurement contracts
- More frequent and detailed financial reporting
- Excessive documentation submission requirements
- Special award-by-award audit requirements
- … and more.
Bob Lloyd, principal of Federal Fund Management Advisor, has helped dozens of subrecipients resolve these types of issues with their pass-through entities in ways that preserved the subaward relationship.
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?
- Sponsored projects administrators
- Federal project directors
- Principal research investigators
- Legal counsels
- Finance directors
- Human resources staff
- Grant and contract managers
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).