A big take-away from the federal grant reforms embodied in the high profile “Super Circular” is the need to understand its ramped up policies on subaward management and monitoring. Recognizing just how often primary recipients pass through federal funds to other organizations, the Office of Management and Budget retooled its guidance. In its guidance, OMB reiterated longstanding policy that the substance of the arrangement is the key determinant in distinguishing between subrecipient and contractor relationships.
Therefore, it’s the content of the subaward agreement between the “pass through entity” and another organization that ultimately determines the nature of the relationship. OMB provides some limited instruction about the features that must be present in a subaward of federal financial assistance. Elsewhere, it also identifies “boilerplate” clauses that need to be inserted into a contract under a grant — a clearly different relationship.
But this guidance is really just a starting point. It’s still up to officials from a pass-through entity to craft their own subaward documents — making sure that they don’t leave required elements out or include things that don’t belong there. This webinar will help you create an effective subaward agreement template.
You’ll learn:
- Characteristics indicative of subawards of federal assistance
- Required data elements that must be included in the award document
- The federal policies that apply to the pass-through entity that must flow through
- Federal policies that don’t apply to subgrants by their terms
- Other subaward guidance OMB is permitting federal agencies to issue
- The specific rules on supplemental requirements crafted by the pass-through entity
- How requirements related to immigration law enforcement kick in
- What generic agreement features it makes good sense to include
- The list of requirements that will apply to “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
- Purchasing managers
- Federal program managers
- Legal counsels
- Finance directors
- Principal investigators and other research staff
- Accounting staff
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