Practicing “Differential Accountability”: Using Special Conditions to Deal with Subrecipient Risk

Webinar • Thursday, June 16, 2022 • 2:00-3:30 p.m. ET

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$249.00 Practicing “Differential Accountability”: Using Special Conditions to Deal with Subrecipient Risk (06.16.22) (On-Demand Recording)
Webinar Details

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

Recommended Field of Study: Specialized Knowledge and Applications

Program Knowledge Level: Basic

Advanced Preparation: None

Issues surrounding the massive amount of federal funding put in place to respond to the COVID-19 pandemic continues to ripple through the grant recipient community. As prime recipients try to maximize the impact of unprecedented funding, they frequently turn to subawarding portions of their grants to subrecipients. When they do so, however, they often find unevenness in the management capacity of those “lower tier” organizations, which can lead to discomfort about accountability.

Unfortunately, a fairly typical pass-through entity’s reaction is to institute numerous oversight procedures that are applied to all subawards, regardless of the track record or demonstrated capacity of the particular subrecipients. This could lead to “micromanagement” and even “overkill.”

The applicable rules in the Office of Management and Budget’s “Uniform Guidance” (2 CFR 200) provide ample support for exercising “differential accountability” instead — fashioning subaward agreements that match unique subrecipient characteristics. OMB lays out additional award conditions that can be imposed to protect federal funds but also identifies flexibilities that allow backing away from actions that waste the time and resources of both pass-through entities and subrecipients.

This webinar captures the OMB policies and demonstrates practical ways they can be used for effective and efficient subrecipient monitoring. You’ll learn about:  

  • Efficacy of employing fixed amount subawards for relatively simple projects and programs
  • Focusing attention of selected subaward budget line items based on vulnerability
  • Conducting procurements on behalf of subrecipients and making subgrants of property
  • Adjusting payment approaches to limit potential financial exposure
  • Differentiating the content and frequency of financial and performance reporting
  • Reducing or adding actions that require pass-through entity approval
  • Creating meaningful programmatic benchmarks that allow for periodic monitoring
  • Tailoring whether and how to sensibly use site visits
  • Mandating upgrades to internal management staffing, training and support


  • Grant and contract managers
  • Sponsored projects administrators
  • Subaward monitors
  • Project directors
  • Executives
  • Legal counsels
  • Finance directors
  • Accounting staffers
  • 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).

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  • Understand special issues confronting pass-through entities contracting with foreign organizations
  • Know which clauses flow down when crafting a subaward
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