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Subrecipient or Contractor? Making the Right Decision

Webinar • Thursday, September 19, 2019 • 2:00-3:30 p.m. ET

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Webinar Details

Prerequisites: Some knowledge of federal grant management and audit requirements is helpful

Recommended Field of Study: Specialized Knowledge and Applications

Program Knowledge Level: Basic

Advanced Preparation: None

The list of federal grant programs that are designed for primary recipients to make awards to other organizations is long. Tens of billions of federal dollars are involved. So it is not surprising that the U.S. Office of Management and Budget, in its so-called “Super Circular,” sought to provide clearer guidance to those involved in the process about whether someone at a “lower tier” is to be treated as a subrecipient receiving federal assistance or a contractor being paid with federal funds for goods and services.

Making the correct determination between subrecipient or contractor has widespread and significant management, accountability and oversight implications. It’s one thing if an award relationship is being forged for the first time. But it’s quite another when the various parties involved have been engaged with one another under the federal program for years. When you look at the agreements that document longstanding arrangements through the prism of the revised federal guidance, the exercise can be daunting and the conclusions uncertain.

This webinar has been designed to help you sort out your lower-tier relationships and to make decisions about the necessary agreements that are defensible, accountable and acceptable to the players. You’ll gain an understanding about: 

  • The distinctions between “assistance” and “procurement” relationships — and why that’s critical
  • How the attributes of relationships cited in the federal rules can be just the start
  • The role played by who “determines the 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 those that do not
  • How to engage in an informed dialogue with other stakeholders about determination decisions
  • The oversight and audit implications once the decision is made

You’re probably not starting from a standing start in most of your “lower tier” federal award relationships. But there are numerous ways to get out of the proper lane. Join Bob Lloyd, principal of Federal Fund Management Advisor and get practical help on how to align — or re-align — what you have been doing with what you should be doing going forward.

Who Should Attend?

  • Accounting staff
  • Grant and contract managers
  • Sponsored projects administrators
  • Subrecipient monitors
  • Project directors
  • Principal investigators
  • Finance directors
  • Legal counsels
  • 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

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This comprehensive resource blends age-old conventional wisdom with the historic changes in OMB’s uniform guidance. You'll benefit from the advice of experts on time and effort reporting, procurement under grants, direct charging certain costs, single audit preparations, subrecipient monitoring and much more. The 500+ page softbound book is a valuable management guide, compliance document and training tool for busy grants managers, program directors, financial officers and auditors at nonprofit organizations, educational institutions, and state and local governments.

This valuable resource will help you and your grants management team:

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  • Make the subrecipient vs. contractor determination
  • Realize the full impact of OMB’s emphasis on internal controls
  • Understand which familiar elements of time and effort reporting have been retained in the uniform guidance ... and which are new
  • Know the nuances of requirements for subrecipient assessment and monitoring
  • Understand contract clauses in agreements for procurement under grants
  • Apply the general tests of allowability
  • Understand special issues confronting pass-through entities contracting with foreign organizations
  • Know which clauses flow down when crafting a subaward
  • Understand what is meant by a 10% de minimis indirect cost rate
  • Audit the vulnerabilities in your grants management operation
  • Understand what is meant by audit "resolution"
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