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Subrecipient or Contractor? Making Correct Case-by-Case Decisions
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Webinar • Thursday, March 8, 2018 • 2:00-3:30 p.m. ET

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$249.00 Subrecipient or Contractor? Making Correct Case-by-Case Decisions (CD Only)
Webinar Details

Subject: Grants Management

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

Recommended Field of Study: Specialized Knowledge and Applications, Auditing (including Government Auditing)

Program Knowledge Level: Basic

Advanced Preparation: None

Guidance issued by the Office of Management and Budget in its “super circular” addresses a dilemma that has been challenging federal grant recipients and auditors for more than 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?” OMB’s new rules now ask, “Subrecipient or contractor”? But, more importantly, they require an organization that receives federal grants and then turns around and awards 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 certainly important. But OMB makes it clear that everyone 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.

OMB attempts to address that issue by outlining characteristics that are “indicative” of each type of relationship. Some of the characteristics have been stated in federal policies before. But OMB has beefed up the guidance in a new key 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’s significant about 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 does a sound agreement look like, and what type of oversight is expected?
  • What is the role of independent auditors in the decision-making process?

Who Should Attend?

  • Grant and contract managers
  • Sponsored projects administrators
  • Legal counsels
  • Finance directors
  • Accounting staff
  • Purchasing agents
  • Project directors
  • 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 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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