There probably isn’t any feature of the “Super Circular” issued by the Office of Management and Budget that is causing more angst than the rules on procurement of goods and services using federal grant funds. For starters, some of the policies were modeled on those that apply to the federal government itself, and those features don’t fit most recipient and subrecipient organizations very well.
Beyond that, there are other subtle and not-so-subtle departures from familiar requirements that will introduce new audit vulnerabilities. That’s why there has been broad resistance to the revised policies and why OMB made unprecedented decisions to allow an extended grace period — up to three fiscal years — before implementation.
The grace period is coming to an end, and recipient and subrecipient organizations are going to have to get with the program by aligning their policies and procedures with key changes such as:
- New guidance on determining whether a relationship is with a subrecipient or a contractor
- Ramped-up code of conduct and mandatory disclosure instructions
- More directions about effective procurement planning
- Expanded discussion of the acceptable methods of purchasing and when to use them
- Tighter requirements about whether sole source purchasing is allowed
- Revised principles that must be used to assess allowability of contract price costing
- Special rules for the procurement of your annual single audit
The new rules are not just about how to buy supplies and equipment; they must also be used when engaging professional services, collaborating on research projects and selecting service providers under social service programs. As you know, the marketplaces for those procurements are very different.
Join us for this webinar, presented by Bob Lloyd, principal of Federal Fund Management Advisor™, to get up to speed on how to rewrite your purchasing procedures to comply with the new requirements for grant-related purchases going forward.
WHO SHOULD ATTEND:
- Grant and contract managers
- Sponsored projects administrators
- Finance directors
- Purchasing agents
- Grant project directors
- Principal investigators
- 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
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.