One of the biggest take-aways from the high profile “Super Circular” grant reforms — now in full implementation — is the need to understand its ramped-up policies on subaward management and monitoring.
Recognizing how often primary recipients pass through federal funds to other organizations, the U.S. Office of Management and Budget retooled its guidance on distinguishing between subrecipient and contractor relationships. OMB reiterated its longstanding policy that the substance of the relationship is the key determinant. In other words, it’s the content of the agreement between the pass-through entity and another organization that ultimately determines the nature of the relationship.
In its guidance, OMB also provided helpful instruction about some of the elements that must be in a financial assistance subaward. In contrast, it identified “boilerplate” clauses that need to be inserted into a contract under a grant — a clearly different relationship. However, this guidance is really just a starting point. It’s still up to officials from a pass-through entity when drafting agreements to ensure they don’t leave out requirements that should be there or include those that don’t belong.
This webinar will help you successfully craft subaward documents by furthering your understanding of:
- The characteristics indicative of subawards of federal assistance
- The required data elements that must be included in award documents
- Which federal policies that apply to the pass-through entity must flow through
- Which federal policies by their terms don’t apply to subgrants
- Other subaward guidance OMB is permitting federal agencies to issue
- The rules related to supplemental requirements crafted by the pass-through entity
- How requirements related to immigration law enforcement might kick in
- What generic agreement features it makes sense to include
- Requirements that will apply to so-called “fixed amount” subawards
Join Bob Lloyd, principal of Federal Fund Management Advisor™, for this timely and comprehensive discussion of this complex subject.
WHO SHOULD ATTEND?
- Grant and contract managers
- Sponsored programs administrators
- Principal investigators and other research staff
- Legal counsels
- Finance directors
- Purchasing managers
- Federal program managers
- Accounting staff
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.