New guidance issued by the U.S. Office of Management and Budget under its grant reform initiative address a conundrum that has been challenging federal grant recipients and their auditors for nearly two decades: What kind of relationship is formed when the recipient enters into an agreement with another organization using federal funds? For a long time, the question was posed as “subrecipient or vendor”?
The new rules now ask “subrecipient or contractor”? More importantly, they require organizations that receive federal grant funds and then turn around and award some of the funds to other entities to make “case-by-case determinations whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.”
What the organization receiving the funds is called is important. OMB makes it clear, however, that all involved should be far more concerned with what is actually going on inside any agreement between the “pass-through entity” and a “lower-tier” organization. And it attempts to address that issue by outlining characteristics that are “indicative” of each type of relationship.
Some of the characteristics have been articulated in federal policies before. OMB has beefed up the guidance in a key new section on subrecipient management and monitoring. And, how the policies are employed have all sorts of implications for pass-through entities, subrecipients, contractors and independent auditors.
Register for this webinar to get a fresh and practical examination of how to make defensible determinations and how, then, to proceed with proper management and oversight. You’ll get answers to questions like:
- What does OMB mean by an “assistance” relationship?
- What does it mean by a “procurement” relationship?
- What applicable program requirements actually serve to create a subrecipient relationship?
- Which applicable federal requirements have to be included in a contractor relationship?
- What is the significance of OMB’s word changes in the instrument selection guidance?
- What role do federal awarding agencies have in the decision-making process?
- Does it really matter what types of organizations are involved in the relationship?
- How do factors like project design, conduct of competition and award “pricing” affect decisions?
- What are the consequences if an incorrect decision is made?
- Are there ways to challenge pass-through entity decisions?
- After a correct decision is made, what type of oversight and audit is expected?
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 several reference works on federal grants management and audits, and currently serves as contributing editor to Federal Grants News, published by Thompson 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
- Accounting staff
- Federal project directors
- Resource development personnel
- Subrecipient staff
- Internal auditors
- External auditors
Can't make the scheduled session? Select the OnDemand Recording to listen in from anywhere with an Internet connection. Available 48 hours after the conference.
Attendees will receive presentation slides as well as access to background materials.
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
Federal Fund Management Advisor™ is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.