OMB’s New Federal Grant Rules on Disclosure — How and When You Must Share Bad News
April 16, 2014 Webinar - Listen On-Demand or Get a CD!
This webinar will help you think through what, how and when you need to make your grantor aware of what is likely to be bad news.
The On-Demand recording will be available immediately upon purchase* as a link within a PDF file of the accompanying written materials. CDs and printed materials are shipped via USPS.
Beware of New Federal Grant Disclosure Requirements
Buried in the new consolidated policies governing federal grants management that the Office of Management and Budget (OMB) rolled out at the end of last year are some new requirements about mandatory disclosure. It’s safe to say that they were not put there at the request of recipients and subrecipients. What they say is that an applicant or recipient or subrecipient of a federal award has an obligation to disclose, in writing, all violations of federal criminal law involving fraud, bribery or gratuity violations potentially affecting the award. For good measure, they add that failure to do so can result in a whole host of enforcement remedies.
The ambiguity associated with the new requirements is glaring. During this webinar, you’ll get answers to the important questions raised by these new rules for recipients and subrecipients:
- How does the federal criminal code define fraud, bribery or a gratuity violation?
- What’s the difference between an allegation and a violation?
- Does it make sense to investigate first?
- What does “in a timely manner” mean?
- How broad or narrow is “potentially affecting the federal award”?
- What are federal awarding agency (and auditors) going to do once they get the disclosure?
Disclosure requirements of various types have been around federal grants and subgrants for years. OMB has carried its longstanding policy on disclosure of “significant developments” that will “materially impair the ability to meet the objective of the federal award” over into the new so-called “Super Circular.” The law and regulations governing the Obama Administration’s Stimulus Program had an even broader disclosure provision and its implementation may have influenced the decision to adopt the new requirement. Meeting either of those requirements has required exercise of judgment. But the new disclosure policy arguably lowers the bar significantly on what needs to be brought to the attention of your awarding agency.
This webinar will help you think through what, how and when you need to make your grantor aware of what is likely to be bad news. And it will emphasize that doing nothing is not an option!
Prerequisites: Some knowledge of federal grant management and audit requirements is helpful but not necessary
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 several 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?
- Governing body members
- Legal counsels
- Finance directors
- Grant and contract managers
- Sponsored programs administrators
- Program managers
- Internal and external auditors
The costs of webinars sponsored by Federal Fund Management Advisor are allowable charges to your federal grants and subgrants. Each of the sets of federal cost principles issued by OMB for federal awards administered by state, local, and tribal governments, colleges and universities, and nonprofit organizations explicitly states that the costs of training for employee development and vocational effectiveness are allowable. For your records, the specific citations are:
- OMB Circular A-21 (2 CFR 220), Appendix A, Paragraph J.51—Colleges and Universities
- OMB Circular A-87 (2 CFR 225), Appendix B, Paragraph 42—State, Local and Tribal Governments
- OMB Circular A-122 (2 CFR 230), Appendix C, Paragraph 49(a)—Nonprofit Organizations
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