Subaward Oversight: OMB’s Never-ending Target

Webinar • Thursday, September 9, 2021 • 2:00-3:30 p.m. ET

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$249.00 Subaward Oversight: OMB’s Never-ending Target (09.09.21) (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

The Office of Management and Budget has told federal agencies to make sure they approve subawards under direct grants and that they hold subrecipients accountable for required performance reporting. A recent “Controller Alert” issued by OMB’s unit responsible for grant administration warned, “All award terms and conditions must clearly and unambiguously notify recipients of their obligations to obtain agency approval for any subawards under 2 CFR 200.308(c)(6).” And it emphasized that those terms and conditions must include subaward reporting as required by the Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR 170.

The renewed attention to subaward oversight shows how the volume of federal assistance being made available under the American Rescue Plan Act (ARPA) involves unprecedented levels of subawarding. So, OMB has focused on the front end of subawards — that they be properly authorized — and the back end — that they be accurately reported. And, sandwiched in the middle, OMB has identified weak subrecipient monitoring as a major risk factor in federal assistance awards.

All of this activity combines to make it a good time for pass-through entities to review the policies necessary to govern the whole lifecycle of a subaward. That’s where this webinar can help. You’ll learn about:

  • How the required prior approval for subawards really works
  • Best practices for soliciting subaward applications
  • The required features of subaward agreements
  • Pass-through entity reporting of subaward obligations under FFATA
  • Acceptable policies for recognition of subrecipient indirect costs
  • Pass-through entity options for requiring financial and performance reporting by subrecipients
  • Verification of subrecipient single audit performance
  • Best practices to address subaward problems or challenges
  • Resolution of subrecipient audit findings
  • Coordinating closeout of subawards with closeout of primary awards

Make sure your organization is effectively showing its compliance in this critical function. Bob Lloyd, principal of Federal Fund Management Advisor™, will conduct this authoritative session. During his long career in federal award implementation, Bob has conducted hundreds of training sessions on effective subrecipient monitoring.


  • Grant and contract managers
  • Sponsored projects administrators
  • Project directors
  • Subaward monitors
  • Finance directors
  • Accounting staff
  • 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

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  • 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
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